G.R. No. 57757 - Philippine National Bank vs. Court of Appeals

Ericsson Telecommunications, Inc. (petitioner), a corporation engaged in the design, engineering, and marketing of telecommunication facilities/systems, with principal office in Pasig City.
City of Pasig (respondent), represented by its City Mayor and City Treasurer, assessed petitioner for local business tax deficiencies.

Assessment Notice dated October 25, 2000: deficiency taxes for 1998 (₱9,466,885.00) and 1999 (₱4,993,682.00), based on gross revenues reported in audited financial statements.
Protest of December 21, 2000: petitioner argued tax base should be gross receipts, not gross revenue.
Second Assessment Notice dated November 19, 2001: deficiency for 2000 (₱4,665,775.51) and 2001 (₱4,710,242.93), again based on gross revenues.
Protest of January 21, 2002: reiterated position on gross receipts. Respondent denied protests and advised of a 30‐day appeal period.

Petitioner filed suit in the Regional Trial Court (RTC) of Pasig, Branch 168, seeking annulment and cancellation of assessments totaling ₱17,262,205.66.
Respondent moved to dismiss for lack of jurisdiction and petitioner’s legal capacity; RTC denied the motion for failure to set a hearing notice.
Respondent declared in default; RTC allowed ex parte evidence and, in its Decision dated March 8, 2004, canceled and set aside the assessment notices.
On appeal, the Court of Appeals (CA) in its Decision dated November 20, 2006 set aside the RTC decision and dismissed the complaint without prejudice for failure to show that Atty. Maria Theresa B. Ramos (who signed the verification and certification of non‐forum shopping) was authorized by the Board of Directors. A motion for reconsideration was denied on February 9, 2007.
Petitioner filed a Petition for Review on Certiorari under Rule 45 with the Supreme Court, challenging (a) CA’s dismissal for alleged lack of authorization, (b) CA’s jurisdiction over respondent’s appeal, and (c) failure to decide merits on the correct tax base.

Did the CA err in dismissing the case for failure to show that the signatory of the verification and certification of non‐forum shopping was authorized by the petitioner’s Board of Directors?
Did the CA have jurisdiction over respondent’s appeal, given that the dispute involves a pure question of law?
Assuming CA jurisdiction, did the CA err in not ruling on the merits of the validity of the deficiency local business tax assessments?