Case Digest (G.R. No. 166273)
Facts:
Metro Rail Transit Corporation v. Court of Tax Appeals and Commissioner of Internal Revenue, G.R. No. 166273, September 21, 2005, the Supreme Court First Division, Ynares‑Santiago, J., writing for the Court.Petitioner Metro Rail Transit Corporation (MRT) filed with the Court of Tax Appeals (CTA) a petition for review on July 4, 2003, challenging Formal Assessment Notices issued by the Commissioner of Internal Revenue directing MRT to pay P595,904,278.01 in alleged deficiencies for expanded withholding tax and value‑added tax for tax years 1995–1997. At the CTA pre‑trial, the parties executed a stipulation of facts and issues approved by the CTA on November 12, 2003.
During the presentation of MRT’s case the CTA scheduled successive hearings. After MRT presented its first witness it sought a resetting from the March 23, 2004 hearing; the March 23 hearing was moved to May 11, 2004 upon MRT’s Urgent Motion for Postponement to gather supporting documents. On May 7, 2004 MRT again moved to postpone to allow its newly retained counsel time to study records still to be turned over by prior counsel. MRT’s new counsel entered and old counsel withdrew on June 11, 2004.
Hearings were rescheduled several times — to June 15, then, at MRT’s request, to July 27, 2004 — the latter reset accompanied by the CTA’s express “final warning” to present evidence. On July 27, 2004 MRT again sought a resetting of the hearing citing negotiations toward a possible compromise with the BIR; the CTA denied the request. In an August 2, 2004 resolution (authored by Presiding Justice Ernesto D. Acosta, concurred in by Associate Justices Lovell R. Bautista and Juanito C. Castaneda, Jr.) the CTA confirmed its bench order of July 27, 2004 and declared that MRT had waived its right to present evidence; the case was reset for September 8, 2004 for respondent’s presentation of evidence.
MRT moved for reconsideration; the CTA denied the motion in an October 18, 2004 resolution, stating that petitioner “clearly lacks interest to prosecute its case” and denying reconsideration "with finality for lack of merit.&qu...(Subscriber-Only)
Issues:
- Did the Court of Tax Appeals gravely abuse its discretion in declaring MRT to have waived its right to present evidence?
- Was the CTA’s denial of MRT’s motion for reconsideration — premised on lack of interest to pro...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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