Commissioner of Internal Revenue v. 3M Philippines, Inc.

EN BANC [C.T.A. EB CASE NO. 1330. June 17, 2021.] (C.T.A. Case No. 8147) COMMISSIONER OF INTERNAL REVENUE , petitioner , vs. 3M PHILIPPINES, INC. , respondent . RESOLUTION For resolution is petitioner's "MOTION FOR RECONSIDERATION (Re: Resolution dated 18 March 2021)" filed on May 21, 2021, praying for the reconsideration of the Court's Resolution dated March 18, 2021, the dispositive portion of which reads: " WHEREFORE , in light of the foregoing considerations, the instant Petition for Annulment of Judgment is hereby DISMISSED for lack of jurisdiction. SO ORDERED ." In support of its Motion, petitioner argues that this Court has jurisdiction to take cognizance of the Petition for Annulment of Judgment. According to the petitioner, even if there is no specific provision in Republic Act No. 9282 and the Revised Rules of the Court of Tax Appeals, the authority of this Court to act on a petition seeking the annulment of judgments is inherent. Such powers necessarily include the authority to amend, modify or reconsider a judgment that has attained finality whenever necessary to serve the ends of justice. Moreover, the higher interests of justice and equity demand the brushing aside of procedural norms, as the rules of procedure are intended to promote rather than defeat substantial justice, and not applied in a very rigid and technical sense. THE COURT'S RULING Petitioner's Motion lacks merit. After a careful examination and consideration of the petitioner's Motion for Reconsideration, it is noted that the main arguments raised in the said Motion are mere reiterations of matters which have already been considered, weighed and resolved in the assailed Decision. Thus, We shall not belabor, in this Resolution, to repeat the disquisitions made therein. Nevertheless, this Court stresses that it is a court of special jurisdiction. As such, it can only take cognizance of such matters as are clearly within its jurisdiction. 1 CAIHTE As admitted by the petitioner in his Motion for Reconsideration, there is no law or rule that grants authority to this Court to exercise jurisdiction over a Petition for Annulment of Judgment. On the contrary, the case of Commissioner of Internal Revenue vs. Kepco Ilijan Corporation , 2 categorically states that this Court, sitting En Banc , has no jurisdiction to take cognizance of a petition for annulment of judgment. According to the Supreme Court, a petition for annulment of judgment is a separate and original action for the purpose of annulling or avoiding a decision that has become final and executory . It is a remedy, independent of the case where the judgment sought to be annulled is rendered, and is not analogous to a motion for reconsideration, appeal, or petition for relief from judgment. 3 A review, however, of the laws which created the CTA and expanded its jurisdiction, the Revised Rules of the CTA, and even the Rules of Court which apply suppletorily, shows that there is no instance in which the CTA, sitting En Banc , is sanctioned to annul its own judgment. 4 Considering that judicial decisions applying or interpreting the laws or the Constitution shall form a part of the legal system of the Philippines, 5 and judicial decisions of the Supreme Court assume the same authority as the statute itself, 6 this Court is bound by the foregoing jurisprudential pronouncements. Accordingly, this Court finds no reason to reverse Our earlier Resolution ordering the dismissal of the subject Petition for lack of jurisdiction. WHEREFORE , premises considered, the instant "MOTION FOR RECONSIDERATION (Re: Resolution dated 18 March 2021)" is hereby DENIED for lack of merit. SO ORDERED. Roman G. del Rosario, P.J., Juanito C. Castaeda, Jr., Erlinda P. Uy, Ma. Belen M. Ringpis-Liban, Catherine T. Manahan, Jean Marie A. Bacorro-Villena and Maria Rowena Modesto-San Pedro, JJ. , concur. Footnotes 1. AT&T Communications Services Philippines, Inc. vs. Commissioner of Internal Revenue , G.R. No. 185969, November 19, 2014. 2. G.R. No. 199422, June 21, 2016. 3. Id. 4. Id. 5. Article 8, New Civil Code. 6. Perfecto S. Floresca, et al. vs. Philex Mining Corporation, et al. , G.R. No. L-30642, April 30, 1985.