Commissioner of Internal Revenue v. Jardine Lloyd Thompson Insurance Brokers, Inc.

EN BANC [C.T.A. EB CASE NO. 1344. August 23, 2017.] (C.T.A. Case No. 8471) COMMISSIONER OF INTERNAL REVENUE , petitioner , vs . JARDINE LLOYD THOMPSON INSURANCE BROKERS, INC. , respondent . RESOLUTION RINGPIS-LIBAN , J p : This resolves Petitioner's "Motion for Reconsideration Re: Decision dated March 21, 2017" filed on April 11, 2017 1 seeking to set aside the Decision 2 promulgated on March 21, 2017 (Assailed Decision). In response thereto, Respondent filed its "Comment (Re: Motion for Reconsideration dated April 7, 2017)" 3 on July 17, 2017. The dispositive portion of the Assailed Decision reads as follows: WHEREFORE , premises considered, the Court hereby DENIES the Petition for Review for lack of merit. The Decision dated April 14, 2015 and the Resolution dated July 23, 2015 of the Second Division in CTA Case No. 8471 are hereby AFFIRMED . 4 After a careful consideration and evaluation of the parties' respective arguments, the Court agrees with Respondent and finds that the issues and arguments raised in Petitioner's Motion for Reconsideration are mere rehash of Petitioner's arguments in his Petition for Review, and have already been amply discussed, passed upon and considered by this Court in the Assailed Decision sought to be reconsidered. Petitioner's arguments constitute neither compelling nor cogent reason to modify, much less reverse the Decision dated March 21, 2017. Thus, the Court finds no cogent reason to modify or reverse the Assailed Decision. ITAaHc WHEREFORE , premises considered, Petitioner Commissioner of Internal Revenue's "Motion for Reconsideration Re: Decision dated March 21, 2017" is hereby DENIED for lack of merit. SO ORDERED. (SGD.) MA. BELEN M. RINGPIS-LIBAN Associate Justice Roman G. del Rosario, P.J., Juanito C. Castaeda, Jr., Lovell R. Bautista, Erlinda P. Uy, Caesar A. Casanova, Esperanza R. Fabon-Victorino and Catherine T. Manahan, JJ. , concur. Cielito N. Mindaro-Grulla, J. , is on official business. Footnotes 1. Rollo , pp. 123-131. 2. Id. at pp. 111-122. 3. Id. at pp. 153-165. 4. Id. at p. 121.