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RIZAL COMMERCIAL BANKING CORPORATION v. CIR

This case has been cited 7 times or more.

	GR No. 184266 2013-11-11	APPLIED FOOD INGREDIENTS COMPANY v. CIR SERENO, C.J.
Furthermore, the CTA, being a court of special jurisdiction, can take cognizance only of matters that are clearly within its jurisdiction.[18] Section 7 of R.A. 1125,[19] as amended by R.A. 9282,[20] specifically provides: SEC. 7. Jurisdiction. The CTA shall exercise:
	GR No. 171251 2012-03-05	LASCONA LAND CO. v. CIR PERALTA, J.
In RCBC v. CIR,[12] the Court has held that in case the Commissioner failed to act on the disputed assessment within the 180-day period from date of submission of documents, a taxpayer can either: (1) file a petition for review with the Court of Tax Appeals within 30 days after the expiration of the 180-day period; or (2) await the final decision of the Commissioner on the disputed assessments and appeal such final decision to the Court of Tax Appeals within 30 days after receipt of a copy of such decision.[13]
	GR No. 177279 2010-10-13	CIR v. RAUL M. GONZALEZ VILLARAMA, JR., J.
Tax assessments by tax examiners are presumed correct and made in good faith, and all presumptions are in favor of the correctness of a tax assessment unless proven otherwise.[58] We have held that a taxpayer's failure to file a petition for review with the Court of Tax Appeals within the statutory period rendered the disputed assessment final, executory and demandable, thereby precluding it from interposing the defenses of legality or validity of the assessment and prescription of the Government's right to assess.[59] Indeed, any objection against the assessment should have been pursued following the avenue paved in Section 229 (now Section 228) of the NIRC on protests on assessments of internal revenue taxes.[60]
	GR No. 175097 2010-02-05	ALLIED BANKING CORPORATION v. CIR DEL CASTILLO, J.
matters that are clearly within its jurisdiction.[21] Section 7 of RA 9282 provides: Sec. 7. Jurisdiction. -- The CTA shall exercise:
	GR No. 169352 2009-02-13	COMMISSIONER OF CUSTOMS v. GELMART INDUSTRIES PHILIPPINES TINGA, J.
Petitioner's failure to file a motion for reconsideration of the assailed decision of the CTA First Division, or at least a petition for review with the CTA en banc, invoking the latter's exclusive appellate jurisdiction to review decisions of the CTA divisions, rendered the assailed decision final and executory. Necessarily, all the arguments professed by petitioner on the validity of the seizure, detention and ultimate forfeiture of the subject shipments have been foreclosed. [14]
	GR No. 164820 2008-12-08	VICTORY LINER v. PABLO RACE CHICO-NAZARIO, J.
The rule is well-settled that points of law, theories, issues, and arguments not adequately brought to the attention of the lower court (or in this case, the appropriate quasi-judicial administrative body) need not be considered by the reviewing court as they cannot be raised for the first time on appeal, much more in a motion for reconsideration as in this case, because this would be offensive to the basic rules of fair play, justice and due process.[19] This last ditch effort to shift to a new theory and raise a new matter in the hope of a favorable result is a pernicious practice that has been consistently rejected.[20] We are not prepared to make a conclusion of law herein that may have far-reaching consequences based on an argument that was belatedly raised and evidently a mere after-thought.
	GR No.123346 2007-12-14	MANOTOK REALTY v. CLT REALTY DEVELOPMENT CORPORATION TINGA, J,
For their part, the Manotoks challenged the validity of the title relied on by CLT, claiming that Dimson's title, the proximate source of CLT's title, was irregularly issued and, hence, the same and subsequent titles flowing therefrom are likewise void. The Manotoks asserted their ownership over Lot 26 and claimed that they derived it from several awardees and/or vendees of the National Housing Authority.[9] The Manotok title likewise traced as its primary source OCT No. 994 which, on 9 September 1918, was transferred to Alejandro Ruiz and Mariano Leuterio who had previously acquired the property on 21 August 1918 by virtue of an "Escritura de Venta" executed by Don Tomas Arguelles and Don Enrique Llopis.[10] On 3 March 1920, Ruiz and Leuterio sold the property to Francisco Gonzalez who held title thereto until 22 August 1938 when the property was transferred to Jose Leon Gonzalez, Consuelo Susana Gonzalez, Juana Francisca Gonzalez, Maria Clara Gonzalez, Francisco Felipe Gonzalez and Concepcion Maria Gonzalez under TCT No. 35486. The lot was then, per annotation dated 21 November 1946, subdivided into seven (7) parcels each in the name of each of the Gonzalezes. [11]