FIRST DIVISION
[G.R. No. 213362. October 8, 2014.]
COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. PRHC PROPERTY MANAGERS, INC., respondent.
NOTICE
Sirs/Mesdames :
Please take notice that the Court, First Division, issued a Resolution dated October 8, 2014which reads as follows:
"G.R. No. 213362 (Commissioner of Internal Revenue v. PRHC Property Managers, Inc.). — After a careful perusal of the records, the Court resolves to DENY the instant petition and AFFIRM the July 2, 2014 Decision 1 of the Court of Tax Appeals (CTA) En Banc in CTA EB No. 980 for failure of the Commissioner of Internal Revenue to show that the CTA En Banc committed any reversible error in denying its petition for review for lack of merit, thereby affirming the October 9, 2012 Amended Decision of the CTA Second Division.
In allowing respondent PRHC Property Managers, Inc.'s presentation of additional documentary evidence after trial through a subsequent motion for reconsideration, the CTA appropriately applied the ruling in BPI-Family Bank v. Court of Appeals2 wherein the Court found it erroneous on the part of the appellate court, i.e., the Court of Appeals, not to have considered the evidence attached by the taxpayer to its motion for reconsideration which clearly proved the latter's entitlement to refund. It was held therein that while strict procedural rules generally frown upon submission of evidence after trial, the law specifically provides that proceedings before the CTA are not governed strictly by the technicalities of evidence, emphasizing that "the paramount consideration remains the ascertainment of truth" and that "[the quest for orderly presentation of issues] should not bar courts from considering undisputed facts to arrive at a just determination of a controversy." ESTaHC
SO ORDERED."
Very truly yours,
(SGD.) EDGAR O. ARICHETADivision Clerk of Court
Footnotes
1. Rollo, pp. 36-48. Penned by Associate Justice Lovell R. Bautista with Presiding Justice Roman G. del Rosario and Associate Justices Juanito C. Castañeda, Jr., Erlinda P. Uy, Caesar A. Casanova, Esperanza R. Fabon-Victorino, Cielito N. Mindaro-Grulla, and Ma. Belen M. Ringpis-Liban, concurring; Associate Justice Amelia R. Cotangco-Manalastas, on leave.
2. 386 Phil. 719, 726 (2000).