Zuellig Pharma Corp. v. Commissioner of Internal Revenue

SPECIAL THIRD DIVISION [C.T.A. CASE NO. 9030. March 2, 2023.] ZUELLIG PHARMA CORPORATION , petitioner , vs. COMMISSIONER OF INTERNAL REVENUE , respondent . DECISION UY , J p : Before this Court is a Petition for Review 1 filed on April 14, 2015 by petitioner, Zuellig Pharma Corporation, against respondent Commissioner of Internal Revenue (CIR), praying that respondent be ordered to refund or issue in favor of petitioner a Tax Credit Certificate (TCC) in the amount of P467,578,787.20, representing petitioner's excess and unutilized creditable withholding taxes (CWT) for the calendar year (CY) ended December 31, 2012. THE PARTIES Petitioner is a corporation duly organized and existing under the laws of the Republic of the Philippines, with principal place of business at Km. 14 West Service Road, South Superhighway corner Edison Avenue, Barangay Sun Valley, Paraaque City. 2 Petitioner is primarily engaged in the business of manufacturing, preparing, compounding, processing, packing, buying, and selling at wholesale and retail, importing and exporting, and otherwise dealing in all kinds of drugs, chemicals, patent, proprietary and other medicines, biological products, oils, dyestuffs, perfumeries, toilet and fancy articles, fancy goods, cosmetics, druggists, sundries, soaps, veterinary products, and generally dealing in goods, wares, merchandise, and personal property of every kind. 3 Petitioner is registered with the Bureau of Internal Revenue (BIR) Large Taxpayers Service with Taxpayer Identification Number (TIN) 000-172-443-000. 4 On the other hand, respondent is the duly appointed CIR vested with authority to carry out all the functions, duties, and responsibilities of said office, including, inter alia , the power to decide, approve, and grant claims for refund of, or issuance of TCC for, overpaid or erroneously paid or collected internal revenue taxes, including excess and unutilized CWT. Respondent holds office at the 5th Floor, BIR National Office Building, Agham Road, Diliman, Quezon City, where he may be served summons and other legal processes of this Court. 5 THE FACTS On April 15, 2013, petitioner filed with the BIR, through the Electronic Filing and Payment System (eFPS), its Annual Income Tax Return (ITR) for the CY ended December 31, 2012. 6 In its Annual ITR for CY 2012, petitioner reported a gross income of P3,206,575,464.00 7 and net taxable income of P602,462,128.00. 8 Consequently, petitioner reported a Regular Corporate Income Tax (RCIT) liability of P180,738,638.40 9 for CY 2012. Petitioner also had income tax credits in the total amount of P788,081,111.80, 10 consisting of prior year's excess credits in the amount of P320,502,324.60 11 and CWT accumulated during the four quarters of CY 2012 in the aggregate amount of P467,578,787.20. 12 After deducting its RCIT liability against its income tax credits for CY 2012, petitioner reported a tax overpayment of P607,342,473.40, 13 computed as follows: Total Gross Income P3,206,575,464.00 Less: Itemized Deductions 2,604,113,336.00 Net Taxable Income P602,462,128.00 RCIT Due (30%) P180,738,638.40 Less: Tax Credits/Payments Prior Year's Excess Credits P320,502,324.60 CWT withheld for the First 3 Quarters P255,616,507.30 CWT withheld for the 4th Quarter 211,962,279.90 467,578,787.20 Total Tax Credits/Payments P788,081,111.80 Tax Overpayment (P607,342,473.40) ============== Petitioner indicated on the face of its Annual ITR for CY 2012 its option to claim for refund of its excess and unutilized CWT for CY 2012. 14 Consequently, petitioner did not carry over its excess and unutilized CWT for CY 2012 in the amount of P467,578,787.20 to the succeeding taxable year. 15 Petitioner utilized its "prior year's excess credits" for CY 2012 in the amount of P320,502,324.60 to pay for its RCIT for CY 2012 amounting to P180,738,638.40. The balance of its prior year's excess credits in the amount of P139,763,686.20 was carried over as "prior year's excess credits" in CY 2013. 16 The amount of P139,763,686.20 was computed as follows: Prior year's excess credits for CY 2012 P320,502,324.60 Less: RCIT Due for CY 2012 180,738,638.40 Remainder of "prior year's excess credits" as of December 31, 2012 (carried over to CY 2013) P139,763,686.20 ============= On May 20, 2013, petitioner filed with the Office of the CIR and the Office of the Deputy CIR-Operations Group a letter dated April 15, 2013 requesting the refund of its excess and unutilized CWT for CY 2012 in the amount of P467,578,787.20. 17 On June 13, 2013, the BIR Large Taxpayers Service issued a Letter of Authority authorizing the revenue officers of Large Taxpayers Regular Audit Division I to examine petitioner's books of accounts and accounting records for the period January 1, 2012 to December 31, 2012 in relation to its claim for refund of excess and unutilized CWT for CY 2012. 18 On April 10, 2015, petitioner filed with the BIR, Large Taxpayers Service a letter supplementing its claim for refund dated April 15, 2013 and prayed for the refund of its excess and unutilized CWT for CY 2012 in the amount of P467,578,787.20, with attached Application for Tax Credits/Refunds (BIR Form No. 1914). 19 With the two (2)-year prescriptive period under Sections 204 (C) and 229 of the National Internal Revenue Code (NIRC) of 1997, as amended, nearing its end, and considering that petitioner has yet to receive respondent's approval or denial of its administrative claim for refund, petitioner filed the instant Petition for Review 20 on April 14, 2015, which was raffled to the Third Division of this Court. On May 5, 2015, respondent filed his Answer 21 interposing special and affirmative defenses, which include, among others, the following: 1) The amount of P467,578,787.20 allegedly representing excess and unutilized CWT for CY 2012 was not properly documented; 2) It is incumbent upon petitioner to discharge its burden of proving entitlement to its claim for refund of alleged excess and unutilized CWT for CY 2012, which includes the fact of withholding of taxes and their subsequent remittance to the BIR; 3) Petitioner must prove that it has complied with the following: a) the claim is filed with the CIR within the two (2)-year period from the date of payment of the tax; (b) it is shown on the return of the recipient that the income payment received was declared as part of the gross income; and (c) the fact of withholding is established by a copy of a statement duly issued by the payor to the payee showing the amount paid and the amount of the tax withheld therefrom; and 4) Petitioner must prove that it has not exercised the option to carry over any excess credits in the succeeding quarters. After the Pre-Trial Conference held on September 1, 2015, the parties filed their Joint Stipulation of Facts and Issues on September 16, 2015. 22 Subsequently, the Court issued the Pre-Trial Order on October 27, 2017. 23 During trial, petitioner presented the following witnesses: 1) Joel R. Ducut, petitioner's Assistant Corporate Controller; 2) Leah A. Estolano, petitioner's Accounts Receivable and Collections Manager; and 3) Katherine O. Constantino, the Court-commissioned ICPA. On the other hand, respondent filed his Manifestation 24 via e-mail on October 8, 2021 stating that he will no longer be presenting any witness, and requesting for a period of thirty (30) days within which to file his Memorandum. The Manifestation was noted in the Resolution 25 dated October 15, 2021 and the parties were given thirty (30) days from notice to submit their respective Memorandum. On December 9, 2021, respondent filed his Memorandum 26 which was noted in the Minute Resolution 27 dated December 11, 2021. On January 10, 2022, petitioner filed its Memorandum 28 via registered mail. On March 11, 2022, petitioner filed a Manifestation 29 with attached copy of the Memorandum 30 filed via registered mail on January 10, 2022. Considering the filing of the parties' respective Memorandum , the instant case was submitted for decision in the Resolution dated March 23, 2022. 31 Hence, this Decision . THE ISSUE As stipulated by the parties, the main issue 32 to be resolved by the Court is: "Whether or not petitioner is entitled to its claim for refund of alleged excess and unutilized CWT for CY 2012 in the amount of P467,578,787.20." Petitioner's arguments: Petitioner argues that it filed its administrative and judicial claims for refund of excess and unutilized CWT for CY 2012 within the two (2)-year prescriptive period provided under Sections 204 (C) and 229 of the NIRC of 1997, as amended. Allegedly, its excess and unutilized CWT for CY 2012 in the amount of P467,578,787.20 are duly substantiated by documentary evidence. Petitioner likewise asserts that the income, upon which the CWT being claimed for refund were withheld, were reported as part of petitioner's declared revenues in its Annual ITR. Finally, petitioner claims that it did not carry over its excess and unutilized CWT for CY 2012 to the succeeding taxable periods. Respondent's counter-arguments: Respondent counter-argues that petitioner failed to exhaust administrative remedies before elevating the case to the Court; thus, the case should be dismissed for prematurity or lack of cause of action. Respondent also claims that petitioner is not entitled to the claim for refund of CWT because it failed to prove by clear and preponderance of evidence its right to the claim, and to comply with Revenue Memorandum Order (RMO) No. 53-98 33 and Revenue Regulations (RR) No. 2-2006. 34 Lastly, respondent asserts that petitioner should prove actual remittance to the BIR of the taxes withheld. THE COURT'S RULING The Petition for Review is partly meritorious. Section 76 of the NIRC of 1997, as amended, enumerates the options given to a taxpayer in the event that the sum of the quarterly tax payments during the taxable year is not equal to the total tax due on the entire taxable income of that year, to wit: "SEC. 76. Final Adjustment Return . Every corporation liable to tax under Section 27 shall file a final adjustment return covering the total taxable income for the preceding calendar or fiscal year. If the sum of the quarterly tax payments made during the said taxable year is not equal to the total tax due on the entire taxable income of that year, the corporation shall either : (A) Pay the balance of the tax still due; or (B) Carry-over the excess credit ; or (C) Be credited or refunded with the excess amount paid , as the case may be. In case the corporation is entitled to a tax credit or refund of the excess estimated quarterly income taxes paid, the excess amount shown on its final adjustment return may be carried over and credited against the estimated quarterly income tax liabilities for the taxable quarters of the succeeding taxable years. Once the option to carry-over and apply the excess quarterly income tax against income tax due for the taxable quarters of the succeeding taxable years has been made, such option shall be considered irrevocable for that taxable period and no application for cash refund or issuance of a tax credit certificate shall be allowed therefor." (Emphasis supplied) Based on the foregoing, two options are available to a corporation whenever it overpays its income tax for the taxable year: (1) to carry over and apply the overpayment as tax credit against the estimated quarterly income tax liabilities of the succeeding taxable years (also known as automatic tax credit) until fully utilized (meaning, there is no prescriptive period); and (2) to apply for a cash refund or issuance of a tax credit certificate within the prescribed period. Such overpayment of income tax is usually occasioned by the over-withholding of taxes on the income payments to the corporate taxpayer. 35 In exercising its option, the corporation must signify in its annual corporate adjustment return (by marking the option box provided in the BIR form) its intention either to carry over the excess credit or to claim a refund. 36 In the instant case, petitioner's Annual ITR for CY 2012 shows that it had income tax credits in the total amount of P788,081,111.80, 37 consisting of prior year's excess credits in the amount of P320,502,324.60 38 and CWT accumulated during the four quarters of CY 2012 in the aggregate amount of P467,578,787.20. 39 Petitioner utilized its "prior year's excess credits" for CY 2012 in the amount of P320,502,324.60 to pay for its RCIT for CY 2012, amounting to P180,738,638.40, 40 leaving a balance of its prior year's excess credits in the amount of P139,763,686.20, and creditable taxes withheld during CY 2012 in the amount of P467,578,787.20. Considering that petitioner indicated on the face of its Annual ITR for CY 2012 its option to claim for refund its excess and unutilized CWT for CY 2012 in the amount of P467,578,787.20, 41 and since only the balance of its prior year's excess credits in the amount of P139,763,686.00 was carried over as "prior year's excess credits" in CY 2013, 42 the amount of P467,578,787.20 may be the subject of a claim for refund or issuance of a TCC under Section 76 of the NIRC of 1997, as amended. Conditions for the grant of refund of, or issuance of a TCC for, excess or unutilized CWT. To exercise the option of refund or tax credit under Section 76 (C) of the NIRC of 1997, as amended, the following requirements 43 must be complied with by the taxpayer to be entitled thereto, to wit: 1. That the claim for refund was filed within the two (2)-year prescriptive period as provided under Section 204 (C) in relation to Section 229 of the NIRC of 1997, as amended; 2. That the fact of withholding is established by a copy of a statement duly issued by the payor (withholding agent) to the payee, showing the amount paid and the amount of tax withheld therefrom; 44 and 3. That the income upon which the taxes were withheld was included in the return of the recipient, i.e. , declared as part of the gross income. First Condition Section 204 (C) in relation to Section 229 of the NIRC of 1997, as amended, respectively provide: "SEC. 204. Authority of the Commissioner to Compromise, Abate and Refund or Credit Taxes . xxx xxx xxx (C) Credit or refund of taxes erroneously or illegally received or penalties imposed without authority, refund the value of internal revenue stamps when they are returned in good condition by the purchaser, and, in his discretion, redeem or change unused stamps that have been rendered unfit for use and refund their value upon proof of destruction. No credit or refund of taxes or penalties shall be allowed unless the taxpayer files in writing with the Commissioner a claim for credit or refund within two (2) years after the payment of the tax or penalty ; Provided, however , That a return filed showing an overpayment shall be considered as a written claim for credit or refund. SEC. 229. Recovery of Tax Erroneously or Illegally Collected . No suit or proceeding shall be maintained in any court for the recovery of any national internal revenue tax hereafter alleged to have been erroneously or illegally assessed or collected, or of any penalty claimed to have been collected without authority, or of any sum alleged to have been excessively or in any manner wrongfully collected, until a claim for refund or credit has been duly filed with the Commissioner ; but such suit or proceeding may be maintained, whether or not such tax, penalty, or sum has been paid under protest or duress. In any case, no such suit or proceeding shall be filed after the expiration of two (2) years from the date of payment of the tax or penalty regardless of any supervening cause that may arise after payment : Provided, however , That the Commissioner may, even without a written claim therefor, refund or credit any tax, where on the face of the return upon which payment was made, such payment appears clearly to have been erroneously paid." (Emphasis supplied) The aforecited provisions are clear: within two (2) years from the date of payment of tax, the claimant must first file an administrative claim with the CIR before filing its judicial claim with the courts of law. Both claims must be filed within a two (2)-year reglementary period. Timeliness of the filing of the claim is mandatory and jurisdictional, and thus the Court cannot take cognizance of a judicial claim for refund filed either prematurely or out of time. 45 In the instant case, petitioner filed its Annual ITR for CY 2012 through the eFPS on April 15, 2013. 46 Counting two (2) years therefrom, petitioner had until April 15, 2015 within which to file both its administrative and judicial claims. Records of the case show that petitioner filed its administrative claim for refund on May 20, 2013 47 and April 10, 2015, 48 and its judicial claim for refund on April 14, 2015; 49 thus, both administrative and judicial claims were timely filed, satisfying the first condition . Petitioner did not fail to exhaust administrative remedies At this point, the Court finds it apt to address respondent's argument that petitioner failed to exhaust administrative remedies before elevating the case to this Court. Allegedly, the filing of a Petition for Review before this Court must be due to the denial by respondent of petitioner's claim or respondent's inaction which is tantamount to the denial of petitioner's claim. Absent these circumstances, the case should be dismissed for prematurity or lack of cause of action. We are not persuaded. Section 229 of the NIRC of 1997, as amended, is clear that the judicial claim for tax refund must be filed within two (2) years from the date of payment of the tax, regardless of any supervening cause that may arise after payment. In Commissioner of Internal Revenue v. Univation Motor Philippines, Inc. (Formerly Nissan Motor Philippines, Inc.) 50 ( Univation case), the Supreme Court held that there is exhaustion of administrative remedies as long as the administrative and judicial claims are filed within the two (2)-year prescriptive period, to wit: " The law only requires that an administrative claim be priorly filed. That is, to give the BIR at the administrative level an opportunity to act on said claim. In other words, for as long as the administrative claim and the judicial claim were filed within the two-year prescriptive period, then there was exhaustion of the administrative remedies ." (Emphasis supplied) In this case, considering that the two (2)-year prescriptive period was about to end on April 15, 2015, and respondent is yet to act on petitioner's administrative claim, petitioner was correct in filing its judicial claim on April 14, 2015. Second and Third Conditions Section 2.58.3 (B) of RR No. 2-98, 51 as amended, provides: "(B) Claims for tax credit or refund of any creditable income tax which was deducted and withheld on income payments shall be given due course only when it is shown that the income payment has been declared as part of the gross income and the fact of withholding is established by a copy of the withholding tax statement duly issued by the payor to the payee showing the amount paid and the amount of tax withheld therefrom. Proof of remittance is the responsibility of the withholding agent ." (Emphasis supplied) From the foregoing, the fact of withholding is established by a copy of the withholding tax statement duly issued by the withholding agent to the payee, showing the amount paid and the amount of tax withheld therefrom. Respondent, however, asserts that petitioner should prove actual remittance to the BIR of the taxes withheld. Respondent is mistaken. In Commissioner of Internal Revenue v. Philippine National Bank , 52 the Supreme Court held that the certificate of creditable tax withheld at source is the competent proof to establish the fact that taxes are withheld. In the same case, the Supreme Court categorically stated that proof of actual remittance is not a condition to claim for a refund of unutilized tax credits, to wit: "Petitioner's posture that respondent is required to establish actual remittance to the Bureau of Internal Revenue deserves scant consideration. Proof of actual remittance is not a condition to claim for a refund of unutilized tax credits . Under Sections 57 and 58 of the 1997 National Internal Revenue Code, as amended, it is the payor-withholding agent, and not the payee-refund claimant such as respondent, who is vested with the responsibility of withholding and remitting income taxes." (Emphasis supplied) From the foregoing, it is clear that there is no requirement on the part of petitioner to prove that it has remitted the tax. Petitioner's compliance with the second condition is shown through the presentation of the relevant Certificates of Creditable Tax Withheld at Source (BIR Form No. 2307). To prove its compliance with the second condition , petitioner submitted the BIR Forms No. 2307 53 and petitioner-prepared Schedule of Creditable Withholding Tax CY 2012. 54 Meanwhile, as to the third condition , petitioner presented its 2012 Annual ITR, 55 Audited Financial Statements (AFS) for CYs 2011 and 2012, 56 Reconciliation of Net Income Per Books against Taxable Income, 57 Schedule of Creditable Withholding Taxes Traced to Books (JV) and Related Invoices, 58 Schedule of Creditable Withholding Taxes According to ATC Codes, 59 Details for Sales Adjustments for CY 2012 per GL code 4000030 amounting to P113,363,626.90 per Trial Balance as of December 31, 2012, 60 and Consolidated Sales Register for CY 2012. 61 The Court-commissioned ICPA examined the aforementioned documents and presented in the ICPA Report dated April 11, 2016 62 the result of the verification as follows: 63 "x x x, we estimate that the amount of P446,735,385.15 are unutilized creditable income taxes withheld for CY 2012 that are properly supported by original BIR Form 2307 computed as follows x x x: Annex Reference Income Payment Tax Withheld CWT properly supported by original BIR Form 2307 Annex 3-a P44,200,197,594.83 P440,273,020.48 CWT duly supported by original BIR Form 2307 with no income payment amount indicated therein Annex 3-b 10,090,269.00 100,902.69 CWT duly supported by original BIR Form 2307 with Petitioners name but no Petitioner's TIN indicated therein Annex 3-c 211,971,500.73 2,080,201.72 CWT duly supported by original BIR Form 2307 with incorrect Petitioner's TIN indicated therein Annex 3-d 426,407,962.46 4,245,540.93 CWT duly supported by original BIR Form 2307 with incorrect income payment amount and Petitioner's TIN indicated therein Annex 3-e 3,963,146.67 35,719.33 P44,852,630,473.69 P446,735,385.15 Out of the properly supported CWT above, we have ascertained that the income payments relative to CWT amounting to P394,539,132.52 were included as part of the Petitioner's books (trial balance as of December 31, 2012 to be presented as Exhibit P-32 ), audited financial statements (previously presented as Exhibit P-5 ) and annual income tax (previously presented as Exhibit P-3 ) as follows x x x: Annex Reference Income Payment Tax Withheld CWT properly supported by original BIR Form 2307 Annex 3-a P42,116,749,625.82 P391,998,720.51 CWT duly supported by original BIR Form 2307 with no income payment amount indicated therein Annex 3-b 6,386,464.79 52,413.00 CWT duly supported by original BIR Form 2307 with Petitioner's name but no Petitioner's TIN indicated therein Annex 3-c 122,269,809.16 1,215,826.21 CWT duly supported by original BIR Form 2307 with incorrect Petitioner's TIN indicated therein Annex 3-d 137,607,740.54 1,236,453.50 CWT duly supported by original BIR Form 2307 with incorrect income payment amount and Petitioner's TIN indicated therein Annex 3-e 7,375,446.23 35,719.30 Total P42,390,389,086.54 P394,539,132.52 " From the foregoing, the Court notes that out of the total claimed CWT for CY 2012 of P467,578,787.20, only the CWT of P391,998,720.51 (under Annex 3-a of Exhibit "P-25") was properly supported by original BIR Forms No. 2307 and the related income payments of P42,116,749,625.82 were traced to the gross income recorded in petitioner's books and reported in its AFS and Annual ITR for CY 2012. However, upon further examination of petitioner's supporting documents, the Court finds that the CWT of P391,998,720.51 must be reduced by P10,133,877.19 for not being properly supported by BIR Forms No. 2307, detailed as follows: Exhibit Payor/Withholding Agent Income Payment CWT Amount CWT supported by BIR Forms No. 2307 with incorrect petitioner's registered name P- 593 EAST AVENUE MEDICAL CENTER P177,555.00 P1,585.31 P- 594 EAST AVENUE MEDICAL CENTER 245,203.20 2,189.31 P- 595 EAST AVENUE MEDICAL CENTER 242,400.00 2,164.29 P- 596 EAST AVENUE MEDICAL CENTER 57,852.00 516.54 P- 597 EAST AVENUE MEDICAL CENTER 75,390.00 673.13 P- 598 EAST AVENUE MEDICAL CENTER 117,000.00 1,044.64 P- 599 EAST AVENUE MEDICAL CENTER 6,495.00 57.99 P- 600 EAST AVENUE MEDICAL CENTER 197,200.00 1,760.71 P- 606 EAST AVENUE MEDICAL CENTER 182,928.30 1,633.29 P- 607 EAST AVENUE MEDICAL CENTER 323,900.00 2,891.96 P- 608 EAST AVENUE MEDICAL CENTER 48,632.00 434.21 P- 609 EAST AVENUE MEDICAL CENTER 17,000.00 151.79 P- 610 EAST AVENUE MEDICAL CENTER 103,581.00 924.83 P- 611 EAST AVENUE MEDICAL CENTER 41,250.00 368.30 P- 612 EAST AVENUE MEDICAL CENTER 216,145.00 1,929.87 P- 730 DYNASTY MANAGEMENT & DEVELOPMENT CORP. 263,490.32 2,352.60 P- 731 DYNASTY MANAGEMENT & DEVELOPMENT CORP. 102,493.10 915.12 P- 985 TAI-PAN DEVELOPMENT, INCORPORATED (GAISANO CITY OZAMIZ) 74,029.00 740.29 P- 986 TAI-PAN DEVELOPMENT, INCORPORATED (GAISANO CITY OZAMIZ) 240,744.00 2,407.44 P- 987 TAI-PAN DEVELOPMENT, INCORPORATED (GAISANO CITY OZAMIZ) 66,749.00 667.49 P- 988 TAI-PAN DEVELOPMENT, INCORPORATED (GAISANO CITY OZAMIZ) 21,969.00 219.69 P 1044 LOPUE'S VALUE STORE-888 26,769.23 267.69 P- 1045 LOPUE'S VALUE STORE-888 12,501.54 125.02 P- 1046 LOPUE'S VALUE STORE-888 5,204.56 52.05 P- 1047 LOPUE'S VALUE STORE-888 21,948.67 219.49 P- 1050 LOPUE'S VALUE STORE-888 17,043.19 170.43 P- 1054 LOPUE'S VALUE STORE-888 31,262.07 312.62 P- 1063 LOPUE'S VALUE STORE-HINIGARAN 28,404.54 284.05 P- 1064 LOPUE'S VALUE STORE-HINIGARAN 33,028.72 330.29 P- 1066 LOPUE'S VALUE STORE-HINIGARAN 110,971.78 1,109.72 P- 1067 LOPUE'S VALUE STORE-HINIGARAN 32,052.63 320.53 P- 1068 LOPUE'S VALUE STORE-HINIGARAN 20,185.15 201.85 P- 1081 LUNG CENTER OF THE PHIL. 13,122.20 117.16 P- 1082 LUNG CENTER OF THE PHIL. 17,349.00 154.90 P- 1083 LUNG CENTER OF THE PHIL. 33,495.60 299.07 P- 1084 LUNG CENTER OF THE PHILIPPINES 98,218.06 876.95 P- 1085 LUNG CENTER OF THE PHILIPPINES 112,689.16 1,006.15 P- 1086 LUNG CENTER OF THE PHIL. 263,739.00 2,354.81 P- 2114 CHERRY FOODARAMA, INC. 2,222,922.00 22,229.22 P- 2115 CHERRY FOODARAMA, INC. 305,756.00 3,057.56 P- 2116 CHERRY FOODARAMA, INC. 74,092.00 740.92 P- 2137 CITY SUPERMARKET, INCORPORATED 3,597.59 35.98 P- 2138 CITY SUPERMARKET, INCORPORATED 934,539.69 9,345.40 P- 2140 CITY SUPERMARKET, INCORPORATED 411,189.00 4,111.89 P- 2141 CITY SUPERMARKET, INCORPORATED 388,549.00 3,885.49 P- 2173 COSTSAVER'S SUPERMARKET, INC. 1,309,791.92 13,097.97 P- 2174 COSTSAVER'S SUPERMARKET, INC. 1,999,776.10 19,997.76 P- 2185 CSI WAREHOUSE CLUB, INC. 1,908,149.34 19,081.49 P- 2187 CSI WAREHOUSE CLUB, INC. 1,702,401.43 17,024.01 P- 2189 CSI WAREHOUSE CLUB, INC. 443,513.68 4,435.14 P- 2190 CSI WAREHOUSE CLUB, INC. 155,376.50 1,553.77 P- 2207 DAVAO CENTRAL WAREHOUSE CLUB, INC. 253,905.00 2,539.05 P- 2208 DAVAO CENTRAL WAREHOUSE CLUB, INC. 270,213.00 2,702.13 P- 2209 DAVAO CENTRAL WAREHOUSE CLUB, INC. 320,894.00 3,208.94 P- 2382 FELCRIS SUPERMARKET, INC. 278,172.00 2,781.72 P- 2383 FELCRIS SUPERMARKET, INC. 2,196,261.00 21,962.61 P- 2641 LOPUE'S VALUE STORE-888 20,500.71 205.01 P- 2643 LOPUE'S VALUE STORE-888 5,980.18 59.80 P- 2644 LOPUE'S VALUE STORE-888 3,734.60 37.35 P- 2645 LOPUE'S VALUE STORE-888 30,388.93 303.89 P- 2646 LOPUE'S VALUE STORE-888 17,808.13 178.08 P- 2647 LOPUE'S VALUE STORE-888 5,980.18 59.80 P- 2648 LOPUE'S VALUE STORE-HINIGARAN 12,035.47 120.35 P- 2649 LOPUE'S VALUE STORE-HINIGARAN 5,634.75 56.35 P- 2650 LOPUE'S VALUE STORE-HINIGARAN 13,621.52 136.22 P- 2651 LOPUE'S VALUE STORE-HINIGARAN 13,404.27 134.04 P- 2652 LOPUE'S VALUE STORE-HINIGARAN 6,560.04 65.60 P- 2654 LOPUE'S VALUE STORE-SAGAY 2,874.98 28.75 P- 2671 LUNG CENTER OF THE PHILIPPINES 50,409.84 450.09 P- 2672 LUNG CENTER OF THE PHILIPPINES 140,000.00 1,250.00 P- 2673 LUNG CENTER OF THE PHILIPPINES 34,200.00 305.36 P- 2674 LUNG CENTER OF THE PHILIPPINES 53,460.00 477.32 P- 2675 LUNG CENTER OF THE PHILIPPINES 163,800.00 1,462.50 P- 2676 LUNG CENTER OF THE PHILIPPINES 26,020.20 232.32 P- 2677 LUNG CENTER OF THE PHILIPPINES 12,629.95 112.77 P- 2678 LUNG CENTER OF THE PHILIPPINES 13,111.30 117.07 P- 2679 LUNG CENTER OF THE PHILIPPINES 20,383.44 182.00 P- 2680 LUNG CENTER OF THE PHILIPPINES 20,800.00 185.71 P- 2681 LUNG CENTER OF THE PHILIPPINES 24,961.00 222.81 P- 2682 LUNG CENTER OF THE PHILIPPINES 35,400.35 316.08 P- 2683 LUNG CENTER OF THE PHILIPPINES 38,400.00 342.86 P- 2684 LUNG CENTER OF THE PHILIPPINES 41,250.00 368.30 P- 2685 LUNG CENTER OF THE PHILIPPINES 41,872.22 373.86 P- 2686 LUNG CENTER OF THE PHILIPPINES 47,565.90 424.70 P- 2687 LUNG CENTER OF THE PHILIPPINES 59,051.99 527.25 P- 2688 LUNG CENTER OF THE PHILIPPINES 64,035.03 571.74 P- 2689 LUNG CENTER OF THE PHILIPPINES 75,060.00 670.18 P- 2690 LUNG CENTER OF THE PHILIPPINES 93,027.04 830.60 P- 2691 LUNG CENTER OF THE PHILIPPINES 96,081.65 857.87 P- 2692 LUNG CENTER OF THE PHILIPPINES 102,960.00 919.29 P- 2693 LUNG CENTER OF THE PHILIPPINES 130,320.00 1,163.57 P- 2694 LUNG CENTER OF THE PHILIPPINES 235,000.00 2,098.21 P- 2695 LUNG CENTER OF THE PHILIPPINES 235,000.00 2,098.21 P- 2696 LUNG CENTER OF THE PHILIPPINES 258,200.00 2,305.36 P- 2697 LUNG CENTER OF THE PHILIPPINES 263,739.00 2,354.81 P- 2698 LUNG CENTER OF THE PHILIPPINES 440,895.00 3,936.56 P- 3417 EAST AVENUE MEDICAL CENTER 124,500.00 1,111.61 P- 3418 EAST AVENUE MEDICAL CENTER 83,895.00 749.06 P- 3419 EAST AVENUE MEDICAL CENTER 66,000.00 589.29 P- 3587 LOPUE'S VALUE STORE 888 3,373.38 33.73 P- 3588 LOPUE'S VALUE STORE 888 41,021.66 410.22 P- 3589 LOPUE'S VALUE STORE 888 31,360.56 313.61 P- 3592 LOPUE'S VALUE STORE 888 44,561.21 445.61 P- 3593 LOPUE'S VALUE STORE 888 13,680.75 136.81 P- 3607 LUNG CENTER OF THE PHILIPPINES 25,704.00 229.50 P- 3608 LUNG CENTER OF THE PHILIPPINES 19,096.00 170.00 P- 3609 LUNG CENTER OF THE PHILIPPINES 3,756.80 33.54 P- 3610 LUNG CENTER OF THE PHILIPPINES 263,088.72 2,349.01 P- 3611 LUNG CENTER OF THE PHILIPPINES 130,320.00 1,163.57 P- 3612 LUNG CENTER OF THE PHILIPPINES 9,800.00 87.50 P- 3613 LUNG CENTER OF THE PHILIPPINES 9,800.00 87.50 P- 3614 LUNG CENTER OF THE PHILIPPINES 83,367.49 744.35 P- 3615 LUNG CENTER OF THE PHILIPPINES 87,042.71 777.17 P- 3616 LUNG CENTER OF THE PHILIPPINES 72,562.50 647.88 P- 3617 LUNG CENTER OF THE PHILIPPINES 9,392.00 83.86 P- 3618 LUNG CENTER OF THE PHILIPPINES 3,398.00 30.34 P- 3619 LUNG CENTER OF THE PHILIPPINES 100,000.00 892.86 P- 3679 TABACO LIBERTY COMMERCIAL CENTER, INC. 54,827.03 548.27 P- 3680 TABACO LIBERTY COMMERCIAL CENTER, INC. 2,417.78 24.17 P- 3681 TABACO LIBERTY COMMERCIAL CENTER, INC. 16,586.35 165.86 P- 3684 TABACO LIBERTY COMMERCIAL CENTER, INC. 58,776.24 587.76 P- 3685 TABACO LIBERTY COMMERCIAL CENTER, INC. 10,435.71 104.35 P- 3686 TABACO LIBERTY COMMERCIAL CENTER, INC. 113,648.88 1,136.48 P- 3699 LOPUE'S SAN SEBASTIAN 20,867.54 208.68 P- 3702 LOPUE'S SAN SEBASTIAN 23,358.22 233.58 P- 3705 LOPUE'S VALUE STORE-HINIGARAN 52,315.26 523.15 P- 3706 LOPUE'S VALUE STORE-HINIGARAN 15,753.83 157.54 P- 3707 LOPUE'S VALUE STORE-HINIGARAN 8,278.46 82.78 P- 3709 LOPUE'S VALUE STORE-HINIGARAN 11,680.59 116.81 P- 3710 LOPUE'S VALUE STORE-HINIGARAN 27,537.78 275.38 P- 3731 DAILY COMMODITIES, INC. 64,079.00 640.79 P- 3733 DAILY COMMODITIES, INC. 18,318.00 183.18 P- 3734 DAILY COMMODITIES, INC. 10,985.00 109.85 P- 4266 CITY SUPERMARKET, INCORPORATED 397,462.39 3,974.62 P- 4272 CITY SUPERMARKET, INCORPORATED 592,082.84 5,920.83 P- 4395 EAST AVENUE MEDICAL CENTER 127,500.00 1,138.39 P- 4396 EAST AVENUE MEDICAL CENTER 180,000.00 1,607.14 P- 4397 EAST AVENUE MEDICAL CENTER 84,372.00 753.32 P- 4398 EAST AVENUE MEDICAL CENTER 375,000.00 3,348.21 P- 4399 EAST AVENUE MEDICAL CENTER 34,850.00 311.16 P- 4400 EAST AVENUE MEDICAL CENTER 120,000.00 1,071.43 P- 4401 EAST AVENUE MEDICAL CENTER 146,895.00 1,311.56 P- 4402 EAST AVENUE MEDICAL CENTER 43,950.00 392.41 P- 4403 EAST AVENUE MEDICAL CENTER 513,980.00 4,589.11 P- 4404 EAST AVENUE MEDICAL CENTER 30,140.00 269.11 P- 4405 EAST AVENUE MEDICAL CENTER 31,410.00 280.45 P- 4406 EAST AVENUE MEDICAL CENTER 36,030.00 321.70 P- 4407 EAST AVENUE MEDICAL CENTER 53,370.00 476.52 P- 4408 EAST AVENUE MEDICAL CENTER 104,260.00 930.89 P- 4409 EAST AVENUE MEDICAL CENTER 385,547.20 3,442.39 P- 4410 EAST AVENUE MEDICAL CENTER 66,600.00 594.64 P- 4444 EVER COMMONWEALTH CENTER, INC. 4,230,684.74 42,306.83 P- 4445 EVER COMMONWEALTH CENTER, INC. 1,633,950.21 16,339.50 P- 4446 EVER COMMONWEALTH CENTER, INC. 170,165.71 1,701.66 P- 4447 EVER COMMONWEALTH CENTER, INC. 451,104.38 4,511.04 P- 4448 EVER COMMONWEALTH CENTER, INC. 74,058.53 740.59 P- 4471 EVER COMMONWEALTH CENTER, INC. 59,752.01 597.53 P- 4472 EVER COMMONWEALTH CENTER, INC. 4,230,684.74 42,306.83 P- 4475 EVER COMMONWEALTH CENTER, INC. 4,636.61 46.36 P- 4476 EVER COMMONWEALTH CENTER, INC. 70,549.50 705.49 P- 4477 EVER COMMONWEALTH CENTER, INC. 171,375.31 1,713.76 P- 4480 EVER COMMONWEALTH CENTER, INC. 11,748.26 117.48 P- 4571 EVER SHOPPERS, INC. 974,366.01 9,743.66 P- 4572 EVER SHOPPERS, INC. 4,416.85 44.16 P- 4573 EVER SHOPPERS, INC. 22,464.75 224.65 P- 4574 EVER SHOPPERS, INC. 106,722.51 1,067.23 P- 4575 EVER SHOPPERS, INC. 110,087.68 1,100.88 P- 4576 EVER SHOPPERS, INC. 150,118.03 1,501.18 P- 4577 EVER SHOPPERS, INC. 8,566.30 85.65 P- 4578 EVER SHOPPERS, INC. 26,130.77 261.30 P- 4698 TAI-PAN DEV'T, INC. (GAISANO CITY OZAMIS) 27,813.00 278.13 P- 4699 TAI-PAN DEV'T, INC. (GAISANO CITY OZAMIS) 13,826.00 138.26 P- 4964 ILOILO GQ ENTERPRISES 1,263,589.85 12,635.92 P- 4965 ILOILO GQ ENTERPRISES 1,983,741.86 19,837.42 P- 4997 JARO SUPERMART 1,129,875.29 11,298.77 P- 4998 JARO SUPERMART 93,766.80 937.68 P- 4999 JARO SUPERMART 875,587.87 8,755.90 P- 5059 LOPUE'S VALUE STORE-HINIGARAN 17,382.32 173.82 P- 5060 LOPUE'S VALUE STORE-HINIGARAN 2,990.09 29.90 P- 5062 LOPUE'S VALUE STORE-HINIGARAN 5,781.60 57.82 P- 5065 LOPUE'S VALUE STORE 888 55,120.55 551.21 P- 5068 LOPUE'S VALUE STORE 888 15,559.62 155.60 P- 5069 LOPUE'S VALUE STORE 888 19,618.62 196.19 P- 5073 LOPUE'S VALUE STORE LVH 88,736.96 887.37 P- 5084 LUNG CENTER OF THE PHILIPPINES 235,000.00 2,098.21 P- 5085 LUNG CENTER OF THE PHILIPPINES 130,320.00 1,163.57 P- 5086 LUNG CENTER OF THE PHILIPPINES 102,960.00 919.29 P- 5087 LUNG CENTER OF THE PHILIPPINES 60,000.00 535.71 P- 5088 LUNG CENTER OF THE PHILIPPINES 38,400.00 342.86 P- 5089 LUNG CENTER OF THE PHILIPPINES 258,200.00 2,305.36 P- 5090 LUNG CENTER OF THE PHILIPPINES 4,200.00 37.50 P- 5091 LUNG CENTER OF THE PHILIPPINES 75,060.00 670.18 P- 5909 EAST AVENUE MEDICAL CENTER 219,069.00 1,955.97 P- 5910 EAST AVENUE MEDICAL CENTER 31,110.00 277.77 P- 5911 EAST AVENUE MEDICAL CENTER 360,000.00 3,214.29 P- 5912 EAST AVENUE MEDICAL CENTER 67,920.00 606.43 P- 5913 EAST AVENUE MEDICAL CENTER 544,200.00 4,858.93 P- 5914 EAST AVENUE MEDICAL CENTER 125,000.00 1,116.07 P- 5915 EAST AVENUE MEDICAL CENTER 30,529.24 272.58 P- 5916 EAST AVENUE MEDICAL CENTER 172,758.00 1,542.48 P- 5917 EAST AVENUE MEDICAL CENTER 127,000.00 1,133.93 P- 6083 FAR EAST NOBLE HOUSE 174,389.06 1,557.05 P- 6084 FAR EAST NOBLE HOUSE 620,565.00 5,540.76 P- 6476 LOPUE'S SAN SEBASTIAN 21,736.54 217.37 P- 6480 LOPUE'S VALUE STORE-HINIGARAN 45,940.20 459.40 P- 6481 LOPUE'S VALUE STORE-888 147,746.29 1,477.46 P- 6494 LUNG CENTER OF THE PHILIPPINES 130,000.00 1,160.71 P- 7328 CHERRY FOODARAMA, INC. 4,426,085.00 44,260.85 P- 7329 CHERRY FOODARAMA, INC. 13,204.00 132.04 P- 7330 CHERRY FOODARAMA, INC. 110,356.00 1,103.56 P- 7331 CHERRY FOODARAMA, INC. 549,658.00 5,496.58 P- 7332 CHERRY FOODARAMA, INC. 228,229.00 2,282.29 P- 7333 CHERRY FOODARAMA, INC. 201,879.00 2,018.79 P- 7441 EAST AVENUE MEDICAL CENTER 30,800.00 275.00 P- 7442 EAST AVENUE MEDICAL CENTER 86,850.00 775.45 P- 7443 EAST AVENUE MEDICAL CENTER 90,281.00 806.08 P- 7444 EAST AVENUE MEDICAL CENTER 49,000.00 437.50 P- 7445 EAST AVENUE MEDICAL CENTER 127,500.00 1,138.39 P- 7446 EAST AVENUE MEDICAL CENTER 116,800.20 1,042.86 P- 7447 EAST AVENUE MEDICAL CENTER 15,390.00 137.41 P- 7484 FLORES, WINSTON JHON TIZON/FARMACIA WIN-J 4,963.90 49.64 P- 7485 FLORES, WINSTON JHON TIZON/FARMACIA WIN-J 102,703.65 1,027.04 P- 7908 JARO SUPERMART 43,699.19 437.00 P- 7909 JARO SUPERMART 319,336.44 3,193.37 P- 8000 TABACO LIBERTY COMMERCIAL CENTER, INC. 9,782.46 97.82 P- 8039 LOPUE'S VALUE STORE-888 1,884.75 18.85 P- 8040 LOPUE'S VALUE STORE-888 4,098.84 40.99 P- 8051 LUNG CENTER OF THE PHILIPPINES 59,658.93 532.67 P- 8052 LUNG CENTER OF THE PHILIPPINES 38,400.00 342.86 P- 8053 LUNG CENTER OF THE PHILIPPINES 40,666.00 363.09 P- 8054 LUNG CENTER OF THE PHILIPPINES 130,320.00 1,163.57 P- 8055 LUNG CENTER OF THE PHILIPPINES 348,240.00 3,109.29 P- 8056 LUNG CENTER OF THE PHILIPPINES 15,085.28 134.69 P- 8057 LUNG CENTER OF THE PHILIPPINES 9,984.00 89.14 P- 8058 LUNG CENTER OF THE PHILIPPINES 6,934.00 61.91 P- 8059 LUNG CENTER OF THE PHILIPPINES 18,212.78 162.61 P- 8060 LUNG CENTER OF THE PHILIPPINES 25,237.56 225.34 P- 8061 LUNG CENTER OF THE PHILIPPINES 107,649.00 961.15 P- 8062 LUNG CENTER OF THE PHILIPPINES 440,895.00 3,936.56 P- 8063 LUNG CENTER OF THE PHILIPPINES 4,200.00 37.50 P- 8064 LUNG CENTER OF THE PHILIPPINES 75,000.00 669.64 P- 8065 LUNG CENTER OF THE PHILIPPINES 4,919.60 43.93 P- 8066 LUNG CENTER OF THE PHILIPPINES 47,925.00 427.90 P- 8067 LUNG CENTER OF THE PHILIPPINES 31,074.15 277.45 P- 8068 LUNG CENTER OF THE PHILIPPINES 75,007.20 669.71 P- 8069 LUNG CENTER OF THE PHILIPPINES 26,023.50 232.35 P- 8070 LUNG CENTER OF THE PHILIPPINES 45,000.00 401.79 P- 8071 LUNG CENTER OF THE PHILIPPINES 11,158.60 99.63 P- 8072 LUNG CENTER OF THE PHILIPPINES 175,600.00 1,567.86 P- 8073 LUNG CENTER OF THE PHILIPPINES 37,998.00 339.27 P- 8074 LUNG CENTER OF THE PHILIPPINES 32,475.40 289.96 P- 8075 LUNG CENTER OF THE PHILIPPINES 4,200.00 37.50 P- 8076 LUNG CENTER OF THE PHILIPPINES 235,000.00 2,098.21 P- 8077 LUNG CENTER OF THE PHILIPPINES 6,566.00 58.63 P- 8078 LUNG CENTER OF THE PHILIPPINES 9,170.00 81.88 P- 8109 MANDURRIAO SUPERMART 616,745.94 6,167.45 P- 8211 DAILY COMMODITIES, INC. 87,967.00 879.67 P- 8212 DAILY COMMODITIES, INC. 33,365.00 333.65 P- 8213 DAILY COMMODITIES, INC. 16,029.00 160.29 P- 8447 SOUTHERN PHILIPPINES MEDICAL CENTER 89,654.07 800.48 P- 8457 SOUTHERN PHILIPPINES MEDICAL CENTER 93,100.00 831.25 P- 9345 CHERRY FOODARAMA, INC. 138,703.00 1,387.03 P- 9346 CHERRY FOODARAMA, INC. 4,165,203.00 41,652.03 P- 9347 CHERRY FOODARAMA, INC. 4,382,899.00 43,828.99 P- 9348 CHERRY FOODARAMA, INC. 1,871,867.00 18,718.67 P- 9554 EAST AVENUE MEDICAL CENTER 424,910.80 3,793.85 P- 9555 EAST AVENUE MEDICAL CENTER 16,900.00 150.89 P- 9556 EAST AVENUE MEDICAL CENTER 96,954.00 865.66 P- 9557 EAST AVENUE MEDICAL CENTER 375,000.00 3,348.21 P- 9558 EAST AVENUE MEDICAL CENTER 77,630.00 693.13 P- 9559 EAST AVENUE MEDICAL CENTER 336,000.00 3,000.00 P- 9560 EAST AVENUE MEDICAL CENTER 382,500.00 3,415.18 P- 9561 EAST AVENUE MEDICAL CENTER 18,000.00 160.71 P- 9562 EAST AVENUE MEDICAL CENTER 33,800.00 301.79 P- 9563 EAST AVENUE MEDICAL CENTER 311,970.00 2,785.45 P- 9564 EAST AVENUE MEDICAL CENTER 296,286.10 2,645.41 P- 9565 EAST AVENUE MEDICAL CENTER 523,082.72 4,670.38 P- 9566 EAST AVENUE MEDICAL CENTER 294,300.00 2,627.68 P- 9567 EAST AVENUE MEDICAL CENTER 108,885.70 972.19 P- 9568 EAST AVENUE MEDICAL CENTER 134,172.00 1,197.96 P- 9569 EAST AVENUE MEDICAL CENTER 317,700.00 2,836.61 P- 9570 EAST AVENUE MEDICAL CENTER 230,930.36 2,061.88 P- 10034 IS MEDICINE CORNER 1,893,364.86 18,933.65 P- 10041 FEGARIDO, MA. MARISSA M. 61,906.31 552.73 P- 10042 FEGARIDO, MA. MARISSA M. 61,445.43 548.62 P- 10065 ISETANN DEPARTMENT STORE, INC. 255,757.24 2,557.57 P- 10249 LUNG CENTER OF THE PHILIPPINES 348,240.00 3,109.29 P- 10250 LUNG CENTER OF THE PHILIPPINES 235,000.00 2,098.21 P- 10251 LUNG CENTER OF THE PHILIPPINES 14,875.00 132.81 P- 10252 LUNG CENTER OF THE PHILIPPINES 15,737.78 140.52 P- 10253 LUNG CENTER OF THE PHILIPPINES 7,500.00 66.96 P- 10254 LUNG CENTER OF THE PHILIPPINES 62,900.00 561.61 P- 10255 LUNG CENTER OF THE PHILIPPINES 2,920.00 26.07 P- 10256 LUNG CENTER OF THE PHILIPPINES 20,710.80 184.92 P- 10257 LUNG CENTER OF THE PHILIPPINES 30,732.87 274.40 P- 10258 LUNG CENTER OF THE PHILIPPINES 44,730.00 399.38 P- 10259 LUNG CENTER OF THE PHILIPPINES 248,400.00 2,217.86 P- 10260 LUNG CENTER OF THE PHILIPPINES 38,400.00 342.86 P- 10261 LUNG CENTER OF THE PHILIPPINES 235,000.00 2,098.21 P- 10262 LUNG CENTER OF THE PHILIPPINES 140,000.00 1,250.00 P- 10263 LUNG CENTER OF THE PHILIPPINES 24,960.00 222.86 P- 10264 LUNG CENTER OF THE PHILIPPINES 64,150.84 572.78 P- 10265 LUNG CENTER OF THE PHILIPPINES 12,072.75 107.79 P- 10266 LUNG CENTER OF THE PHILIPPINES 25,454.55 227.27 P- 10342 MANDURRIAO SUPERMART 500,279.81 5,002.81 P- 10589 PATIENT CARE CORPORATION 9,923,400.00 99,234.00 P- 10590 PATIENT CARE CORPORATION 10,609,812.00 106,098.12 P- 12558 PUREGOLD PRICE CLUB, INC. 11,774,196.62 117,741.97 P- 12559 PUREGOLD PRICE CLUB, INC. 167,882.75 1,678.83 P- 12560 PUREGOLD PRICE CLUB, INC. 225,823.50 2,258.24 P- 12561 PUREGOLD PRICE CLUB, INC. 1,466,301.19 14,663.02 P- 12570 PUREGOLD PRICE CLUB, INC. 12,880,882.71 128,808.84 P- 12571 PUREGOLD PRICE CLUB, INC. 56,411,770.05 564,117.70 P- 12572 PUREGOLD PRICE CLUB, INC. 528,159.63 5,281.60 P- 12573 PUREGOLD PRICE CLUB, INC. 530,523.77 5,305.24 P- 12574 PUREGOLD PRICE CLUB, INC. 51,430,008.41 514,300.08 P- 12575 PUREGOLD PRICE CLUB, INC. 190,038.58 1,900.39 P- 12576 PUREGOLD PRICE CLUB, INC. 252,860.87 2,528.61 P- 13428 ILOILO GQ ENTERPRISES 2,644,644.39 26,446.45 P- 13611 MANDURRIAO SUPERMART 789,421.22 7,894.22 P- 13843 PUREGOLD PRICE CLUB, INC. 9,740,582.28 97,405.83 P- 13844 PUREGOLD PRICE CLUB, INC. 250,883.29 2,508.83 P- 13845 PUREGOLD PRICE CLUB, INC. 1,418,462.81 14,184.63 P- 13846 PUREGOLD PRICE CLUB, INC. 503,540.44 5,035.40 P- 13847 PUREGOLD PRICE CLUB, INC. 386,058.98 3,860.59 P- 13849 PUREGOLD PRICE CLUB, INC. 140.53 1.41 P- 13850 PUREGOLD PRICE CLUB, INC. 4,009,699.12 40,096.99 P- 13851 PUREGOLD PRICE CLUB, INC. 40,991,655.41 409,916.56 P- 14252 EVER PLUS SUPERSTORE, INC.-ROCES 115,549.57 1,155.49 P- 14253 EVER PLUS SUPERSTORE, INC.-ROCES 1,522.50 15.23 P- 14254 EVER PLUS SUPERSTORE, INC.-ROCES 1,013,854.11 10,138.54 P- 14255 EVER PLUS SUPERSTORE, INC.-ROCES 30,944.82 309.45 P- 14256 EVER PLUS SUPERSTORE, INC.-ROCES 49,561.18 495.60 P- 14257 EVER PLUS SUPERSTORE, INC.-ROCES 1,164.35 11.64 P- 14266 EVER PLUS SUPERSTORE, INC.-MARULAS 1,121.40 11.21 P- 14267 EVER PLUS SUPERSTORE, INC.-MARULAS 11,641.36 116.40 P- 14268 EVER PLUS SUPERSTORE, INC.-MARULAS 25,176.16 251.78 P- 14269 EVER PLUS SUPERSTORE, INC.-MARULAS 284,690.63 2,846.89 P- 14270 EVER PLUS SUPERSTORE, INC.-MARULAS 2,218.13 22.19 P- 14271 EVER PLUS SUPERSTORE, INC.-MARULAS 1,627,793.91 16,277.93 P- 14306 EVER SHOPPERS, INC. 16,983.75 169.84 P- 14307 EVER SHOPPERS, INC. 786,198.86 7,861.98 P- 14308 EVER SHOPPERS, INC. 2,787,120.95 27,871.20 P- 14309 EVER SHOPPERS, INC. 191,289.13 1,912.89 P- 14310 EVER SHOPPERS, INC. 117,599.14 1,176.00 P- 14311 EVER SHOPPERS, INC. 78,811.77 788.12 P- 14312 EVER SHOPPERS, INC. 848.89 8.49 P- 14313 EVER SHOPPERS, INC. 8,465,03 84.65 P- 14315 EVER COMMONWEALTH CENTER, INC. 131,538.99 1,315.38 P- 14316 EVER COMMONWEALTH CENTER, INC. 26,426.17 264.25 P- 14317 EVER COMMONWEALTH CENTER, INC. 780,369.35 7,803.70 P- 14318 EVER COMMONWEALTH CENTER, INC. 11,764.44 117.64 P- 14319 EVER COMMONWEALTH CENTER, INC. 6,241,025.25 62,410.25 P- 14320 EVER COMMONWEALTH CENTER, INC. 63,213.56 632.13 P- 14321 EVER COMMONWEALTH CENTER, INC. 13,600.64 136.01 P- 14322 EVER COMMONWEALTH CENTER, INC. 207,747.20 2,077.48 P- 14323 EVER COMMONWEALTH CENTER, INC. 144,980.15 1,449.80 P- 14324 EVER COMMONWEALTH CENTER, INC. 59,587.50 595.87 P- 14325 EVER COMMONWEALTH CENTER, INC. 4,603.72 46.04 P- 14326 EVER COMMONWEALTH CENTER, INC. 1,880,185.66 18,801.87 P- 14327 EVER PLUS SUPERSTORE, INC.-SAPANG PALAY 1,884.75 18.85 P- 14328 EVER PLUS SUPERSTORE, INC.-SAPANG PALAY 126,079.56 1,260.80 P- 14329 EVER PLUS SUPERSTORE, INC.-SAPANG PALAY 55,564.28 555.63 P- 14330 EVER PLUS SUPERSTORE, INC.-SAPANG PALAY 3,994.41 39.94 P- 14331 EVER PLUS SUPERSTORE, INC.-SAPANG PALAY 7,770.00 77.70 P- 14332 EVER PLUS SUPERSTORE, INC.-SAPANG PALAY 1,776,585.47 17,765.84 P- 14333 EVER PLUS SUPERSTORE, INC.-SAPANG PALAY 2,080.77 20.81 P- 14334 EVER COMMONWEALTH CENTER, INC. 1,277,706.86 12,777.08 P- 14335 EVER COMMONWEALTH CENTER, INC. 27,105.75 271.06 P- 14336 EVER COMMONWEALTH CENTER, INC. 167,246.67 1,672.47 P- 14337 EVER COMMONWEALTH CENTER, INC. 171,497.59 1,714.97 P- 14338 EVER COMMONWEALTH CENTER, INC. 405,393.77 4,053.94 P- 14339 EVER COMMONWEALTH CENTER, INC. 7,212.61 72.13 P- 14340 EVER COMMONWEALTH CENTER, INC. 47,383.54 473.83 P- 14341 EVER COMMONWEALTH CENTER, INC. 5,903,733.33 59,037.33 P- 14343 EVER COMMONWEALTH CENTER, INC. 7,381.50 73.82 P- 14344 EVER COMMONWEALTH CENTER, INC. 13,542.09 135.42 P- 14345 EVER COMMONWEALTH CENTER, INC. 5,119.87 51.20 P- 14346 EVER COMMONWEALTH CENTER, INC. 66,145.89 661.46 P- 14347 EVER COMMONWEALTH CENTER, INC. 35,723.62 357.24 P- 14348 EVER COMMONWEALTH CENTER, INC. 1,048,526.27 10,485.26 P- 14349 EVER PLUS SUPERSTORE, INC.-SAPANG PALAY 4,830.70 48.30 P- 14350 EVER PLUS SUPERSTORE, INC.-SAPANG PALAY 6,472.16 64.72 P- 14351 EVER PLUS SUPERSTORE, INC.-SAPANG PALAY 1,625,430.49 16,254.31 P- 14352 EVER PLUS SUPERSTORE, INC.-SAPANG PALAY 91, 570.93 915.70 P- 14353 EVER PLUS SUPERSTORE, INC.-SAPANG PALAY 45,249.57 452.49 P- 14354 EVER PLUS SUPERSTORE, INC.-SAPANG PALAY 8,211.11 82.11 P- 14355 EVER SHOPPERS, INC. 738,490.91 7,384.92 P- 14356 EVER SHOPPERS, INC. 10,547.25 105.47 P- 14357 EVER SHOPPERS, INC. 82,320.97 823.21 P- 14358 EVER SHOPPERS, INC. 136,553.46 1,365.53 P- 14359 EVER SHOPPERS, INC. 206,902.19 2,069.02 P- 14360 EVER SHOPPERS, INC. 7,236.16 72.36 P- 14361 EVER SHOPPERS, INC. 13,083.19 130.84 P- 14362 EVER SHOPPERS, INC. 4,159,874.14 41,598.74 P- 14364 EVER PLUS SUPERSTORE, INC.-ROCES 136,923.09 1,369.22 P- 14365 EVER PLUS SUPERSTORE, INC.-ROCES 5,318.25 53.18 P- 14366 EVER PLUS SUPERSTORE, INC.-ROCES 849,251.21 8,492.52 P- 14367 EVER PLUS SUPERSTORE, INC.-ROCES 28,669.13 286.70 P- 14368 EVER PLUS SUPERSTORE, INC.-ROCES 48,386.78 483.86 P- 14611 ROBINSONS SUPERMARKET CORPORATION 56,809.67 568.11 P- 14612 ROBINSONS SUPERMARKET CORPORATION 1,140,192.49 11,401.96 P- 14613 ROBINSONS SUPERMARKET CORPORATION 1,448,252.26 14,482.37 P- 14614 ROBINSONS SUPERMARKET CORPORATION 81,990.66 819.91 P- 14615 ROBINSONS SUPERMARKET CORPORATION 278,843.48 2,788.42 P- 14616 ROBINSONS SUPERMARKET CORPORATION 79,012,751.88 790,127.25 P- 14617 ROBINSONS SUPERMARKET CORPORATION 8,062,580.31 80,625.80 P- 14618 ROBINSONS SUPERMARKET CORPORATION 7,669,074.38 76,690.87 P- 14619 ROBINSONS SUPERMARKET CORPORATION 958,551.83 9,585.58 P- 16492 PUREGOLD PRICE CLUB, INC. 1,756,190.85 17,561.91 P- 16493 PUREGOLD PRICE CLUB, INC. 724,173.30 7,241.73 P- 16494 PUREGOLD PRICE CLUB, INC. 1,347,874.50 13,478.75 P- 16495 PUREGOLD PRICE CLUB, INC. 2,079,035.72 20,79037 P- 16496 PUREGOLD PRICE CLUB, INC. 51,325,463.50 513,254.63 P- 16497 PUREGOLD PRICE CLUB, INC. 12,794,024.28 127,940.25 P- 16498 PUREGOLD PRICE CLUB, INC. 11,907,727.30 119,077.28 P- 18311 CSI WAREHOUSE CLUB, INC. 990,262.34 9,902.62 P- 18313 CSI WAREHOUSE CLUB, INC. 1,509,082.04 15,090.82 P- 18315 CSI WAREHOUSE CLUB, INC. 172,986.32 1,729.86 P- 18318 COSTSAVERS SUPERMARKET, INC. 242,839.07 2,428.39 P- 18319 COSTSAVERS SUPERMARKET, INC. 18,172.11 181.72 P- 18325 COSTSAVERS SUPERMARKET, INC. 1,678,802.83 16,788.03 P- 18369 EAST AVENUE MEDICAL CENTER 135,527.20 1,227.92 P- 18370 EAST AVENUE MEDICAL CENTER 127,000.00 1,133.93 P- 18371 EAST AVENUE MEDICAL CENTER 165,852.00 1,480.82 P- 18372 EAST AVENUE MEDICAL CENTER 66,289.80 591.87 P- 18373 EAST AVENUE MEDICAL CENTER 30,720.00 274.29 P- 18536 LUNG CENTER OF THE PHILIPPINES 23,823.52 212.71 P- 18537 LUNG CENTER OF THE PHILIPPINES 34,306.90 306.31 P- 18538 LUNG CENTER OF THE PHILIPPINES 38,400.00 342.86 P- 18539 LUNG CENTER OF THE PHILIPPINES 11,090.00 99.02 P- 18540 LUNG CENTER OF THE PHILIPPINES 10,130.00 90.45 P- 18541 LUNG CENTER OF THE PHILIPPINES 6,934,00 61.91 P- 18542 LUNG CENTER OF THE PHILIPPINES 2,217.84 19.80 P- 18543 LUNG CENTER OF THE PHILIPPINES 31,950.00 285.27 P- 19294 EVER COMMONWEALTH CENTER, INC. 1,370.25 13.70 P- 19295 EVER COMMONWEALTH CENTER, INC. 1,207.50 12.08 P- 19296 EVER COMMONWEALTH CENTER, INC. 30,606.54 306.06 P- 19297 EVER COMMONWEALTH CENTER, INC. 210,134.08 2,101.35 P- 19298 EVER COMMONWEALTH CENTER, INC. 51,248.01 512.48 P- 19299 EVER COMMONWEALTH CENTER, INC. 731,174.67 7,311.74 P- 19306 EVER PLUS SUPERSTORE, INC.-ROCES 49,527.16 495.27 P- 19307 EVER PLUS SUPERSTORE, INC.-ROCES 162,148.31 1,621.48 P- 19308 EVER PLUS SUPERSTORE, INC.-ROCES 615,924.78 6,159.26 P- 19309 EVER PLUS SUPERSTORE, INC.-ROCES 7,917.00 79.17 P- 19310 EVER PLUS SUPERSTORE, INC.-ROCES 33,020.56 330.20 P- 19311 EVER PLUS SUPERSTORE, INC.-ROCES 2,285.75 22.85 P- 19312 EVER PLUS SUPERSTORE, INC.-LORES 33,035.07 330.35 P- 19313 EVER PLUS SUPERSTORE, INC.-LORES 417,317.32 4,173.17 P- 19314 EVER PLUS SUPERSTORE, INC.-LORES 1,024,930.04 10,249.31 P- 19315 EVER PLUS SUPERSTORE, INC.-LORES 8,218.87 82.20 P- 19316 EVER PLUS SUPERSTORE, INC.-LORES 4,110.75 41.10 P- 19317 EVER PLUS SUPERSTORE, INC.-LORES 1,536.59 15.37 P- 19318 EVER PLUS SUPERSTORE, INC.-LORES 2,459.73 24.59 P- 19319 EVER PLUS SUPERSTORE, INC.-LORES 14,656.89 146.56 P- 19419 EVER SHOPPERS, INC. 894,794.11 8,947.93 P- 19420 EVER SHOPPERS, INC. 3,904.87 39.05 P- 19421 EVER SHOPPERS, INC. 17,398.50 173.99 P- 19422 EVER SHOPPERS, INC. 88,912.39 889.12 P- 19423 EVER SHOPPERS, INC. 117,395.52 1,173.95 P- 19424 EVER SHOPPERS, INC. 239,335.36 2,393.34 P- 19425 EVER SHOPPERS, INC. 8,159.71 81.60 P- 19426 EVER SHOPPERS, INC. 29,273.30 292.73 P- 19427 EVER SHOPPERS, INC. 2,732,301.71 27,323.01 P- 19428 EVER COMMONWEALTH CENTER, INC. 3,055.98 30.56 P- 19429 EVER COMMONWEALTH CENTER, INC. 182,487.43 1,824.88 P- 19430 EVER COMMONWEALTH CENTER, INC. 179,262.46 1,792.61 P- 19431 EVER COMMONWEALTH CENTER, INC. 536,129.80 5,361.29 P- 19432 EVER COMMONWEALTH CENTER, INC. 10,412.44 104.11 P- 19433 EVER COMMONWEALTH CENTER, INC. 62,941.45 629.40 P- 19434 EVER COMMONWEALTH CENTER, INC. 5,732,386.06 57,323.86 P- 19954 LUNG CENTER OF THE PHILIPPINES 258,200.00 2,305.36 P- 19955 LUNG CENTER OF THE PHILIPPINES 235,000.00 2,098.21 P- 19956 LUNG CENTER OF THE PHILIPPINES 130,320.00 1,163.57 P- 19958 LUNG CENTER OF THE PHILIPPINES 90,833.26 811.01 P- 19959 LUNG CENTER OF THE PHILIPPINES 235,000.00 2,098.21 P- 19960 LUNG CENTER OF THE PHILIPPINES 89,263.68 797.00 P- 19961 LUNG CENTER OF THE PHILIPPINES 133,655.70 1,193.35 P- 19962 LUNG CENTER OF THE PHILIPPINES 82,996.88 741.04 P- 19963 LUNG CENTER OF THE PHILIPPINES 75,060.00 670.18 P- 19964 LUNG CENTER OF THE PHILIPPINES 20,383.44 182.00 P- 19965 LUNG CENTER OF THE PHILIPPINES 190,960.00 1,705.00 P- 20522 DYNASTY MANAGEMENT & DEVELOPMENT CORP./G. SOUTH DAVAO 173,450.89 1,548.67 P- 20523 DYNASTY MANAGEMENT & DEVELOPMENT CORP./G. SOUTH DAVAO 24,420.20 218.04 P- 21154 EAST AVENUE MEDICAL CENTER 162,000.00 1,446.43 P- 21155 EAST AVENUE MEDICAL CENTER 157,020.00 1,401.96 P- 21219 TAN, GINA R./GINN PHARMACY 22,451.68 224.52 P- 21293 EAST AVENUE MEDICAL CENTER 78,858.60 704.09 P- 21294 EVER PLUS SUPERSTORE, INC. 1,058,380.48 10,583.80 P- 21295 EVER PLUS SUPERSTORE, INC.-RECTO 591,108.74 5,911.09 P- 21296 EVER PLUS SUPERSTORE, INC.-RECTO 20,104.41 201.04 P- 21297 EVER PLUS SUPERSTORE, INC.-RECTO 266,283.34 2,662.83 P- 21298 EVER PLUS SUPERSTORE, INC.-RECTO 25,380.18 253.80 P- 21299 EVER SHOPPERS, INC. 1,919,452.09 19,194.52 P- 21300 EVER PLUS SUPERSTORE, INC.-11TH AVE. 890,477.33 8,904.78 P- 21301 EVER PLUS SUPERSTORE, INC.-RECTO 1,327,628.80 13,276.30 P- 21302 EVER PLUS SUPERSTORE, INC. 126,976.77 1,269.77 Subtotal 538,909,471.76 5,363,435.27 CWT supported by BIR Forms No. 2307 with incorrect/unreadable TIN of petitioner P- 2041 BEROVAN MARKETING, INC. 23,021,353.00 230,213.53 P- 18716 DYNASTY MANAGEMENT & DEVELOPMENT CORP./G. TABUNOK 92,808.00 928.08 P- 18717 DYNASTY MANAGEMENT & DEVELOPMENT CORP./G. TABUNOK 17,137.00 171.37 P- 13129 DMT DRUG CORPORATION 10,714.28 107.14 P- 13139 DRUGMAN DRUG HOUSE 48,616.61 486.17 Subtotal 23,190,628.89 231,906.29 CWT supported by BIR Form No. 2307 with incorrect TIN/name of petitioner P- 655 DYNASTY MANAGEMENT & DEVELOPMENT, INC. 71,284.00 712.84 Subtotal 71,284.00 712.84 CWT supported by BIR Form No. 2307 but amount of income payment was not indicated P- 13133 DR. AMANDO D. COPE MEMORIAL HOSPITAL, INC. 39,830.21 398.30 Subtotal 39,830.21 398.30 CWT supported by BIR Forms No. 2307 but petitioner's registered address was not indicated P- 428 CENTRAL LUZON DOCTORS' HOSPITAL 374,888.44 3,748.89 P- 628 ELIZABETH Q. LIM-SIOSON 16,178.46 161.78 P- 1023 KIDAPAWAN DOCTORS HOSPITAL, INC. 336,866.37 3,007.74 P- 2042 BETHANY HOSPITAL, INC. 104,755.34 1,047.55 P- 2043 BETHANY HOSPITAL, INC. 64,891.64 648.92 P- 2044 BETHANY HOSPITAL, INC. 95,950.60 959.51 P- 2045 BETHANY HOSPITAL, INC. 137,511.21 1,375.11 P- 2046 BETHANY HOSPITAL, INC. 66,474.20 664.74 P- 2180 COURT OF APPEALS 29,339.29 293.39 P- 2192 CSI WAREHOUSE CLUB, INC. 23,410.71 234.11 P- 2967 RIVERA MEDICAL CENTER, INC. 383,277.00 3,832.77 P- 2968 RIVERA MEDICAL CENTER, INC. 19,274.00 192.47 P- 3833 SECOND WAVE CORPORATION 181,838.00 1,818.38 P- 6356 FEGARIDO, MA. MARISSA M. 70,597.04 630.33 P- 7508 FEGARIDO, MA. MARISSA M. 82,751.63 738.85 P- 7509 FEGARIDO, MA. MARISSA M. 81,786.90 730.24 P- 7510 FEGARIDO, MA. MARISSA M. 80,967.02 722.92 P- 7519 FEGARIDO, MA. MARISSA M. 106,624.83 952.00 P- 7520 FEGARIDO, MA. MARISSA M. 93,706.64 836.67 P- 8217 TAY EDUARDO WONG (NEW FARMACIA SUY HOO) 423,415.16 3,779.46 P- 8672 WESTERN VISAYAS MEDICAL CENTER 225,446.43 2,254.46 P- 8673 WESTERN VISAYAS MEDICAL CENTER 437,500.00 4,375.00 P- 8674 WESTERN VISAYAS MEDICAL CENTER 218,750.00 2,187.50 P- 8675 WESTERN VISAYAS MEDICAL CENTER 385,969.64 3,859.70 P- 8676 WESTERN VISAYAS MEDICAL CENTER 136,160.71 1,361.61 P- 8677 WESTERN VISAYAS MEDICAL CENTER 213,765.18 2,137.65 P- 8678 WESTERN VISAYAS MEDICAL CENTER 286,218.75 2,862.19 P- 8679 WESTERN VISAYAS MEDICAL CENTER 291,964.29 2,919.64 P- 8680 WESTERN VISAYAS MEDICAL CENTER 11,430.00 114.30 P- 10389 MMG HOSPITAL AND HEALTH SERVICES COOP. OF TAGUM 40,352.94 403.53 P- 10391 MMG HOSPITAL AND HEALTH SERVICES COOP. OF TAGUM 126,468.23 1,264.68 P- 10392 MMG HOSPITAL AND HEALTH SERVICES COOP. OF TAGUM 56,419.30 564.19 P- 11631 VADUZ MARKETING, INC. 15,048,659.00 150,486.59 P- 12977 CAVITE MEDICAL CENTER, INC. 54,676.00 546.76 P- 13157 EURO MED LABORATORIES PHIL., INC. 8,811,691.07 88,116.91 P- 13919 SANDOVAL DISTRIBUTORS, INC. 6,425,901.40 64,259.01 P- 14026 UERM MEMORIAL MEDICAL CENTER, INC. 133,133.93 1,331.34 P- 17861 PROTACIO MEDICAL SERVICES, INC. 2,330.36 23.30 P- 18138 UERM MEMORIAL MEDICAL CENTER, INC. 189,613.10 1,896.14 P- 18153 VADUZ MARKETING, INC. 10,086,858.00 100,868.58 P- 18348 DAVAO FARMACIA SOUTHERN, INC. 1,875,650.00 18,756.50 P- 18392 GOLDEN DRUG 19,381.15 173.04 P- 18579 MARIKINA VALLEY MEDICAL CENTER, INC. 341,226.56 3,412.27 P- 18580 MARIKINA VALLEY MEDICAL CENTER, INC. 69,454.30 694.57 P- 18581 MARIKINA VALLEY MEDICAL CENTER, INC. 162,670.80 1,626.71 P- 18659 POROCO INDUSTRIES CORPORATION 160,353.91 1,603.54 P- 18745 CENTRAL LUZON DOCTORS HOSPITAL 183,909.91 1,839.10 P- 18746 CENTRAL LUZON DOCTORS HOSPITAL 87,206.14 872.07 P- 18790 KIDAPAWAN DOCTORS HOSPITAL, INC. 154,913.15 1,383.15 P- 18813 MARY CHILES HOSPITAL, INC. 333,406.94 2,976.85 P- 18982 SACRED HEART HOSPITAL OF MALOLOS, INC. 249,964.24 2,499.64 P- 19731 PAGSANJAN MEDICAL CLINIC, INC. 161,403.86 1,614.04 P- 19732 PAGSANJAN MEDICAL CLINIC, INC. 251,762.46 2,517.62 P- 19733 PAGSANJAN MEDICAL CLINIC, INC. 83,989.53 839.90 P- 19734 PAGSANJAN MEDICAL CLINIC, INC. 100,753.71 1,007.54 P- 19735 PAGSANJAN MEDICAL CLINIC, INC. 132,283.28 1,322.83 P- 19736 PAGSANJAN MEDICAL CLINIC, INC. 105,080.25 1,050.80 P- 19820 SAINT LOUIS UNIVERSITY, INC. 58,234.64 582.35 P- 19821 SAINT LOUIS UNIVERSITY, INC. 34,821.43 348.21 P- 19902 MARIKINA VALLEY MEDICAL CENTER, INC. 127,054.52 1,270.54 P- 19940 LOPUE'S SAN SEBASTIAN 1,416.13 14.16 P- 20066 PATIENT CARE CORPORATION 6,869,780.00 68,697.80 P- 20067 PATIENT CARE CORPORATION 10,504,515.00 105,045.15 P- 20218 WESTERN VISAYAS MEDICAL CENTER 443,883.93 4,438.84 P- 20219 WESTERN VISAYAS MEDICAL CENTER 167,857.14 1,678.57 P- 20221 WESTERN VISAYAS MEDICAL CENTER 415,401.79 4,154.02 P- 20755 SAINT LOUIS UNIVERSITY, INC. 889,587.95 8,895.89 P- 21172 JAC MEDICAL DISTRIBUTORS 42,570.92 380.10 P- 21177 JAC MEDICAL DISTRIBUTORS 700.00 6.25 P- 21245 AB PHARMA, INC. 42,415.18 424.15 P- 21246 AB PHARMA, INC. 19,297.98 192.98 P- 21247 AB PHARMA, INC. 30,148.79 301.49 P- 21248 AB PHARMA, INC. 3,844.08 38.44 P- 21249 AB PHARMA, INC. 24,168.07 241.68 P- 21250 AB PHARMA, INC. 24,930.02 249.30 P- 21251 AB PHARMA, INC. 33,329.15 333.29 P- 21252 AB PHARMA, INC. 3,063.34 30.63 P- 21253 AB PHARMA, INC. 52,530.18 525.30 P- 21254 AB PHARMA, INC. 27,225.83 272.26 P- 21255 AB PHARMA, INC. 10,046.53 100.46 P- 21256 AB PHARMA, INC. 10,145.87 101.46 P- 21266 BUREAU OF CORRECTIONS 85,266.00 852.66 P- 21290 DEPARTMENT OF HEALTH 321,750.00 3,217.50 P- 21313 HOSPITAL MANAGEMENT SERVICES, INC. 3,397,565.00 33,975.65 P- 21327 MARY CHILES HOSPITAL, INC. 48,784.80 435.58 P- 21328 MARY CHILES HOSPITAL, INC. 240,652.91 2,148.68 P- 21329 MARY CHILES HOSPITAL, INC. 450,095.48 4,018.71 P- 21339 NATIONAL CENTER FOR MENTAL HEALTH 1,053,605.64 10,536.05 P- 21416 TAISHO PHARMACEUTICALS PHILIPPINES, INC. 1,041,666.70 20,833.33 P- 21418 VADUZ MARKETING, INC. 16,449,493.00 164,494.93 Subtotal 93,357,071.00 941,235.49 CWT supported by BIR Forms No. 2307 without signature of payor's authorized representative P- 15193 HOLY FAMILY HEALTH SERVICES, INC. 3,456.72 34.57 P- 15198 HOLY FAMILY HEALTH SERVICES, INC. 49,689.00 496.89 P- 15541 ANGELES MEDICAL CENTER, INC. 179,405.65 1,794.06 P- 15542 ANGELES MEDICAL CENTER, INC. 309,966.89 3,099.67 P- 15698 CHERRY FOODARAMA, INC. 161,064.00 1,610.64 P- 15699 CHERRY FOODARAMA, INC. 583,844.00 5,838.44 P- 15846 DYNA DRUG CORPORATION 27,583,956.00 275,839.56 P- 15847 DYNA DRUG CORPORATION 141,227,497.00 1,412,274.97 P- 15848 DYNA DRUG CORPORATION 186,962,149.00 1,869,621.49 P- 16357 NEW SACRED HEART PHARMACY-DUMAGUETE BRANCH 50,006.82 500.07 P- 16358 NEW SACRED HEART PHARMACY-DUMAGUETE BRANCH 10,886.25 108.86 P- 16362 NEW SACRED HEART PHARMACY-DUMAGUETE BRANCH 104,906.22 1,049.06 P- 16817 TAN, LEO A. 42,900.70 429.01 P- 16818 TAN, LEO A. 478,055.44 4,780.55 P- 16819 TAN, LEO A. 390,884.62 3,908.85 P- 16821 TAN, LEO A. 347,255.77 3,472.56 P- 18234 ARGENT BUSINESS CONSULTANTS AND STORES SPECIALISTS, INC. (TRADE NAME: MED EXPRESS DRUGSTORE) 210,865.33 2,108.62 P- 18921 PREMIERE GENERAL HOSPITAL OF NUEVA ECIJA, INC. 60,046.00 600.46 P- 18922 PREMIERE GENERAL HOSPITAL OF NUEVA ECIJA, INC. 39,758.00 397.58 P- 18923 PREMIERE GENERAL HOSPITAL OF NUEVA ECIJA, INC. 170,853.00 1,708.53 P- 18924 PREMIERE GENERAL HOSPITAL OF NUEVA ECIJA, INC. 228,531.00 2,285.31 P- 18925 PREMIERE GENERAL HOSPITAL OF NUEVA ECIJA, INC. 208,466.00 2,084.66 P- 18926 PREMIERE GENERAL HOSPITAL OF NUEVA ECIJA, INC. 74,523.00 745.23 Subtotal 359,478,966.41 3,594,789.64 CWT without supporting BIR Forms No. 2307 P- 2653 LOPUE'S VALUE STORE-HINIGARAN 30,912.53 309.13 P- 21479 TAGUM DOCTORS HOSPITAL, INC. 109,023.05 1,090.23 Subtotal 139,935.58 1,399.36 TOTAL P1,015,187,187.85 P10,133,877.19 In sum, petitioner sufficiently proved its compliance with the requisites for granting a CWT refund but only in the amount of P381,864,843.32 out of the total claim of P467,578,787.20, as computed below: Annex Reference (Exh. P-25) Income Payments CWT Amount CWT properly supported by original BIR Forms 2307 Annex 3-a P42,116,749,625.82 P391,998,720.51 Less: CWT without proper BIR Forms 2307 per this Court's further verification 1,015,187,187.85 10,133,877.19 Refundable Excess CWT P41,101,562,437.97 P381,864,843.32 Petitioner's alleged failure to submit the documents listed under RMO No. 53-98 and RR No. 2-2006 in its administrative claim is not fatal to its judicial claim for refund. Respondent asserts that petitioner is not entitled to the claim for refund of CWT because the latter failed to submit the required documents under RMO No. 53-98 and RR No. 2-2006 when it filed its administrative claim. Respondent is mistaken. A perusal of RMO No. 53-98 and RR No. 2-2006 reveals that there is nothing in said regulations which requires the submission of all the documents specified therein before a taxpayer may be entitled to a refund. In the Univation case, the Supreme Court held that failure to submit the complete documents at the administrative level is not fatal to a claim for refund at the judicial level brought about by the inaction of the CIR, to wit: "Petitioner CIR argued that failure of the respondent to submit the required complete documents as required by Revenue Memorandum Order No. 53-98 and Revenue Regulations No. 2-2006 rendered the petition with the CTA dismissible on the ground of lack of jurisdiction. It reasoned out that when a taxpayer prematurely filed a judicial claim with the CTA, the latter has no jurisdiction over the appeal. In the instant case, respondent's failure to submit the complete documents at the administrative level did not render its petition for review with the CTA dismissible for lack of jurisdiction . At this point, it is necessary to determine the grounds relied upon by a taxpayer in filing its judicial claim with the CTA. The case of Pilipinas Total Gas, Inc. v. Commissioner of Internal Revenue is instructive, thus: A distinction must, thus, be made between administrative cases appealed due to inaction and those dismissed at the administrative level due to the failure of the taxpayer to submit supporting documents. If an administrative claim was dismissed by the CIR due to the taxpayer's failure to submit complete documents despite notice/request, then the judicial claim before the CTA would be dismissible, not for lack of jurisdiction, but for the taxpayer's failure to substantiate the claim at the administrative level. When a judicial claim for refund or tax credit in the CTA is an appeal of an unsuccessful administrative claim, the taxpayer has to convince the CTA that the CIR had no reason to deny its claim. It, thus, becomes imperative for the taxpayer to show the CTA that not only is he entitled under substantive law to his claim for refund or tax credit, but also that he satisfied all the documentary and evidentiary requirements for an administrative claim. It is, thus, crucial for a taxpayer in a judicial claim for refund or tax credit to show that its administrative claim should have been granted in the first place. Consequently, a taxpayer cannot cure its failure to submit a document requested by the BIR at the administrative level by filing the said document before the CTA. In this case, it was the inaction of petitioner CIR which prompted respondent to seek judicial recourse with the CTA . Petitioner CIR did not send any written notice to respondent informing it that the documents it submitted were incomplete or at least require respondent to submit additional documents. As a matter of fact, petitioner CIR did not even render a Decision denying respondent's administrative claim on the ground that it had failed to submit all the required documents. Considering that the administrative claim was never acted upon, there was no decision for the CTA to review on appeal per se . However, this does not preclude the CTA from considering evidence that was not presented in the administrative claim with the BIR. Thus, RA No. 1125 states: Section 8. Court of record; seal; proceedings . The Court of Tax Appeals shall be a court of record and shall have a seal which shall be judicially noticed. It shall prescribe the form of its writs and other processes. It shall have the power to promulgate rules and regulations for the conduct of the business of the Court, and as may be needful for the uniformity of decisions within its jurisdiction as conferred by law, but such proceedings shall not be governed strictly by technical rules of evidence. The law creating the CTA specifically provides that proceedings before it shall not be governed strictly by the technical rules of evidence. The paramount consideration remains the ascertainment of truth. Thus, the CTA is not limited by the evidence presented in the administrative claim in the Bureau of Internal Revenue. The claimant may present new and additional evidence to the CTA to support its case for tax refund. Cases filed in the CTA are litigated de novo as such, respondent "should prove every minute aspect of its case by presenting, formally offering and submitting x x x to the Court of Tax Appeals all evidence x x x required for the successful prosecution of its administrative claim." Consequently, the CTA may give credence to all evidence presented by respondent, including those that may not have been submitted to the CIR as the case is being essentially decided in the first instance." (Emphasis supplied) In this case, petitioner filed the instant Petition for Review on April 14, 2015 considering that the two (2)-year prescriptive period under Sections 204 (C) and 229 of the NIRC of 1997, as amended, was nearing its end, with petitioner having yet to receive respondent's approval or denial of its administrative claim for refund. Applying the Supreme Court's pronouncement in the Univation case, respondent cannot invoke petitioner's alleged non-compliance with RMO No. 53-98 and RR No. 2-2006 as basis for the denial of petitioner's claim for tax refund or credit. Moreover, as explained by the Supreme Court in Pilipinas Total Gas, Inc. v. Commissioner of Internal Revenue 64 ( Total case), RMO No. 53-98 does not require the submission of the complete documents enumerated therein in order for a taxpayer's claim for refund or credit to be granted, to wit: "As can be gleaned from the above, RMO No. 53-98 is addressed to internal revenue officers and employees, for purposes of equity and uniformity, to guide them as to what documents they may require taxpayers to present upon audit of their tax liabilities. Nothing stated in the issuance would show that it was intended to be a benchmark in determining whether the documents submitted by a taxpayer are actually complete to support a claim for tax credit or refund of excess unutilized excess VAT. As expounded in Commissioner of Internal Revenue v. Team Sual Corporation (formerly Mirant Sual Corporation) : The CIR's reliance on RMO 53-98 is misplaced. There is nothing in Section 112 of the NIRC, RR 3-88 or RMO 53-98 itself that requires submission of the complete documents enumerated in RMO 53-98 for a grant of a refund or credit of input VAT. 65 The subject of RMO 53-98 states that it is a "Checklist of Documents to be Submitted by a Taxpayer upon Audit 66 of his Tax Liabilities . . ." In this case, TSC was applying for a grant of refund or credit of its input tax. There was no allegation of an audit being conducted by the CIR. Even assuming that RMO 53-98 applies, it specifically states that some documents are required to be submitted by the taxpayer "if applicable." Moreover, if TSC indeed failed to submit the complete documents in support of its application, the CIR could have informed TSC of its failure, consistent with Revenue Memorandum Circular No. (RMC) 42-03. 67 However, the CIR did not inform TSC of the document it failed to submit, even up to the present petition. The CIR likewise raised the issue of TSC's alleged failure to submit the complete documents only in its motion for reconsideration of the CTA Special First Division's 4 March 2010 Decision. Accordingly, we affirm the CTA EB's finding that TSC filed its administrative claim on 21 December 2005, and submitted the complete documents in support of its application for refund or credit of its input tax at the same time. As explained earlier and underlined in Team Sual above, taxpayers cannot simply be faulted for failing to submit the complete documents enumerated in RMO No. 53-98, absent notice from a revenue officer or employee that other documents are required . Granting that the BIR found that the documents submitted by Total Gas were inadequate, it should have notified the latter of the inadequacy by sending it a request to produce the necessary documents in order to make a just and expeditious resolution of the claim . Indeed, a taxpayer's failure with the requirements listed under RMO No. 53-98 is not fatal to its claim for tax credit or refund of excess unutilized excess VAT. This holds especially true when the application for tax credit or refund of excess unutilized excess VAT has arrived at the judicial level. After all, in the judicial level or when the case is elevated to the Court, the Rules of Court governs. Simply put, the question of whether the evidence submitted by a party is sufficient to warrant the granting of its prayer lies within the sound discretion and judgment of the Court." (Emphasis supplied) While the Total case involves a claim for refund or credit of unutilized value-added tax, We find that the principle enunciated therein is also applicable to a claim for refund or issuance of TCC of unutilized CWT. Thus, based on the Total case, a taxpayer's failure to submit the requirements listed under RMO No. 53-98 is not fatal to its claim for tax credit or refund considering that RMO No. 53-98 is merely a guide to revenue officers as to what documents they may require taxpayers to present upon audit of their tax liabilities, and is never intended to be a benchmark in determining whether the documents submitted by a taxpayer are actually complete to support a claim for tax credit or refund. Likewise, RR No. 2-2006 merely imposes a penalty for the non-submission of the information or statement required therein, without resulting to an outright denial of the claim for tax refund or credit. In view of the foregoing, there is no basis to conclude that petitioner's alleged non-compliance with RMO No. 53-98 and RR No. 2-2006 is fatal to its claim for refund or credit. It bears stressing that the Court of Tax Appeals is a court of record, and the cases filed before it are litigated de novo and party litigants should prove every minute aspect of its case. 68 This Court is not precluded from accepting petitioner's evidence, even assuming these were not presented at the administrative level. 69 The question of whether the evidence submitted by a party is sufficient to warrant the granting of its prayer lies within the sound discretion and judgment of the Court. 70 WHEREFORE , in light of the foregoing considerations, the instant Petition for Review is PARTIALLY GRANTED . Accordingly, respondent is ORDERED TO REFUND OR ISSUE A TAX CREDIT CERTIFICATE in favor of petitioner, in the reduced amount of P381,864,843.32 , representing petitioner's excess and unutilized CWT for CY ended December 31, 2012. SO ORDERED. (SGD.) ERLINDA P. UY Associate Justice Ma. Belen M. Ringpis-Liban and Maria Rowena Modesto-San Pedro, JJ. , concur. Footnotes 1. Docket Vol. 1, pp. 10 to 18. 2. Joint Stipulation of Facts and Issues (JSFI) , Stipulation of Facts, par. 1, Docket Vol. 1, p. 238. 3. JSFI , Stipulation of Facts, par. 2, Docket Vol. 1, p. 238. 4. JSFI , Stipulation of Facts, par. 3, Docket Vol. 1, p. 239; Exhibit "P-2", Docket Vol. 1, p. 440. 5. JSFI , Stipulation of Facts, par. 4, Docket Vol. 1, p. 239. 6. Petition for Review (PFR) , par. 4, Docket Vol. 1, p. 11 vis--vis Exhibit "P-3", Docket Vol. 1, pp. 441 to 448. 7. PFR , par. 5, Docket Vol. 1, p. 11 vis--vis Exhibit "P-3", Line 20C, Docket Vol. 1, p. 443. 8. PFR , par. 5, Docket Vol. 1, p. 11, vis--vis Exhibit "P-3", Line 26, Docket Vol. 1, p. 443. 9. PFR , par. 5, Docket Vol. 1, p. 11, vis--vis Exhibit "P-3", Line 32, Docket Vol. 1, p. 443. 10. PFR , par. 6, Docket Vol. 1, pp. 11 to 12, vis--vis Exhibit "P-3", Line 33R, Docket Vol. 1, p. 443. 11. PFR , par. 6, Docket Vol. 1, pp. 11 to 12, vis--vis Exhibit "P-3", Line 33A, Docket Vol. 1, p. 443. 12. PFR , par. 6, Docket Vol. 1, pp. 11 to 12, vis--vis Exhibit "P-3", Lines 33F and 33H, Docket Vol. 1, p. 443. 13. PFR , par. 7, Docket Vol. 1, p. 12, vis--vis Exhibit "P-3", Line 37, Docket Vol. 1, p. 444. 14. PFR , par. 8, Docket Vol. 1, p. 12, vis--vis Exhibit "P-3", Docket Vol. 1, p. 444. 15. PFR , par. 8, Docket Vol. 1, p. 12, vis--vis Exhibit "P-14", Schedule 7, Line 1, Docket Vol. 2, p. 527. 16. PFR , par. 9, Docket Vol. 1, p. 12, vis--vis Exhibit "P-14", Schedule 7, Line 1, Docket Vol. 2, p. 527. 17. PFR , par. 10, Docket Vol. 1, p. 13, vis--vis Exhibits "P-9-a" and "P-9-b", Docket Vol. 2, pp. 508 to 509. 18. PFR , par. 11, Docket Vol. 1, p. 13, vis--vis Exhibit "P-11", Docket Vol. 2, pp. 514 to 517. 19. PFR , par. 12, Docket Vol. 1, p. 13, vis--vis Exhibit "P-10", Docket Vol. 2, pp. 510 to 513. 20. Docket Vol. 1, pp. 10 to 18. 21. Docket Vol. 1, pp. 82 to 86. 22. Docket Vol. 1, pp. 238 to 245. 23. Docket Vol. 1, pp. 252 to 259. 24. Docket Vol. 4, pp. 1785 to 1787. 25. Docket Vol. 4, p. 1797. 26. Docket Vol. 4, pp. 1799 to 1808. 27. Docket Vol. 4, p. 1810. 28. Docket Vol. 4, pp. 1814 to 1846. 29. Docket Vol. 4, pp. 1850 to 1852. 30. Docket Vol. 4, pp. 1853 to 1884. 31. Docket Vol. 4, pp. 1889 to 1890. 32. JSFI , Stipulated Issues for Resolution, Docket Vol. 1, p. 239. 33. SUBJECT: Checklist of Documents to be Submitted by a Taxpayer upon Audit of his Tax Liabilities as well as of the Mandatory Reporting Requirements to be Prepared by a Revenue Officer, all of which Comprise a Complete Tax Docket. 34. SUBJECT: Mandatory Attachments of the Summary Alphalist of Withholding Agents of Income Payments Subjected to Tax Withheld at Source (SAWT) to Tax Returns with Claimed Tax Credits due to Creditable Tax Withheld at Source and of the Monthly Alphalist of Payees (MAP) Whose Income Received Have Been Subjected to Withholding Tax to the Withholding Tax Remittance Return Filed by the Withholding Agent/Payor of Income Payments. 35. University Physicians Services, Inc.-Management, Inc. v. Commissioner of Internal Revenue , G.R. No. 205955, March 7, 2018. 36. Systra Philippines, Inc. v. Commissioner of Internal Revenue , G.R. No. 176290, September 21, 2007. 37. Exhibit "P-3", Line 33R, Docket Vol. 1, p. 443. 38. Exhibit "P-3", Line 33A, Docket Vol. 1, p. 443. 39. Exhibit "P-3", Lines 33F and 33H, Docket Vol. 1, p. 443. 40. Exhibit "P-3", Line 32, Docket Vol. 1, p. 443. 41. Exhibit "P-3", Docket Vol. 1, p. 444. 42. The amount stated in the Annual ITR for CY 2013 is P139,763,686 instead of P139,763,686.20 because amounts in centavos are not entered in the ITR; Exhibit "P-14", Schedule 7, Line 1, Docket Vol. 2, p. 527. 43. Republic of the Philippines, represented by the Commissioner of Internal Revenue v. Team (Phils.) Energy Corporation (formerly Mirant (Phils.) Energy Corporation) , G.R. No. 188016, January 14, 2015; Banco Filipino Savings and Mortgage Bank v. Commissioner of Internal Revenue , G.R. No. 155682, March 27, 2007; and United International Pictures AB v. Commissioner of Internal Revenue , G.R. No. 168331, October 11, 2012. 44. Section 2.58.3 (B) of RR No. 2-98. 45. Commissioner of Internal Revenue v. San Miguel Corporation/San Miguel Corporation v. Commissioner of Internal Revenue , G.R. Nos. 180740 & 180910, November 11, 2019. 46. Exhibit "P-3", Docket Vol. 1, pp. 441 to 448. 47. Exhibits "P-9-a" and "P-9-b", Docket Vol. 2, pp. 508 to 509. 48. Exhibit "P-10", Docket Vol. 2, pp. 510 to 513. 49. Docket Vol. 1, pp. 10 to 18. 50. G.R. No. 231581, April 10, 2019. 51. SUBJECT: Implementing Republic Act No. 8424, "An Act Amending the National Internal Revenue Code, as amended" relative to the Withholding on Income subject to the Expanded Withholding Tax and Final Withholding Tax, Withholding of Income Tax on Compensation, Withholding of Creditable Value-Added Tax and Other Percentage Taxes. 52. G.R. No. 180290, September 29, 2014. 53. Exhibits "P-41" to "P-290", "P-292" to "P-1097", "P-1099" to "P-1483", "P-1485" to "P-2652" to "P-2654" to "P-3215", "P-3217" to "P-4020", "P-4022" to "P-4355", "P-4357" to "P-5439", "P-5441" to "P-5889", "P-5975", "P-5981" to "P-6552", "P-6555" to "P-7451", "P-7453" to "P-9417", "P-9419" to "P-11193", "P-11195" to "P-11197", "P-11199", "P-11200", "P-11202" to "P-11222", "P-11224" to "P-11268", "P-11273" to "P-11284", "P-11286", "P-11288", "P-11289", "P-11291" to "P-11302", "P-11304", "P-11331", "P-11334" to "P-11337", "P-11339", "P-11341" to "P-11343", "P-11345" to "P-11360", "P-11362" to "P-11382", "P-11384" to "P-11392", "P-11394" to "P-11403", "P-11405" to "P-11419", "P-11421" to "P-11424", "P-11432" to "P-11440", "P-11443", "P-11444", "P-11446", "P-11448" to "P-11461", "P-11463", "P-11474" to "P-11481", "P-11483" to "P-11490", "P-11505" to "P-11512", "P-11527", "P-11530", "P-11532" to "P-11536", "P-11570" to "P-11988", "P-11991", "P-11992", "P-11996" to "P-12098", "P-12101" to "P-12527", "P-12529" to "P-12597", "P-12599" to "P-12663", "P-12665" to "P-13145", "P-13147" to "P-18910", "P-18912" to "P-18999", "P-19003" to "P-19202", "P-21467" to "P-21469" to "P-21493", and "P-466081", Hard Drive. 54. Exhibit "P-28", Hard Drive. 55. Exhibit "P-3", Docket Vol. 1, pp. 441 to 448. 56. Exhibit "P-5", Docket Vol. 1, pp. 458 to 500, Docket Vol. 2, p. 501. 57. Annex 8, ICPA CD. 58. Annex 37, ICPA CD. 59. Annex 2, ICPA CD. 60. Exhibit "P-21495", Hard Drive. 61. Exhibit "P-37", Hard Drive. 62. Exhibit "P-25", Docket Vol. 1, pp. 307 to 344 and CD. 63. Exhibit "P-25", p. 35, Docket Vol. 1, p. 342. 64. G.R. No. 207112, December 8, 2015. 65. Underscoring by the Supreme Court. 66. Emphasis by the Supreme Court. 67. Underscoring by the Supreme Court. 68. Commissioner of Internal Revenue v. Manila Mining Corporation , G.R. No. 153204, August 31, 2005. 69. Commissioner of Internal Revenue v. Philippine National Bank , G.R. No. 180290, September 29, 2014. 70. Pilipinas Total Gas, Inc. v. Commissioner of Internal Revenue , G.R. No. 207112, December 8, 2015.