REPUBLIC ACT No.

1125 June 16, 1954 under Rule one hundred twenty-six of the Rules of Court for the disqualification of judicial
officers. No person who has once serviced in the Court in a permanent capacity, either
AN ACT CREATING THE COURT OF TAX APPEALS as Presiding Judge or as Associated Judge thereof, shall be qualified to practice as
counsel before the Court for a period of one year from his separation therefrom for any
Section 1. Court; Judges; qualifications; salary; tenure. - There is hereby created a Court cause.
of Tax Appeals which shall consist of a Presiding Judge and two Associate Judges, each
of whom shall be appointed by the President, with the consent of the Commission on Section 6. Place of office. - The Court of Tax Appeals shall have its office in the City of
Appointments. The Presiding Judge shall be so designated in the commission issued to Manila, and shall hold hearings at such time and place as it may, by order in writing,
him by the President, and the Associate Judges shall have precedence according to the designate with a view to assuring a reasonable opportunity for taxpayers to appear with
date o their commissions. The Presiding Judge shall receive a compensation of thirteen a little inconvenience and expense as practicable.
thousand pesos per annum and shall have the same qualifications, rank, category and
privileges as the Presiding Judge of the Court of Industrial Relations. The Associate Section 7. Jurisdiction. - The Court of Tax Appeals shall exercise exclusive appellate
Judges shall each receive a compensation of twelve thousand pesos per annum and jurisdiction to review by appeal, as herein provided.
shall have the same qualifications, rank, category and privileges as a member of the
Court of Industrial Relations. The Presiding Judge and the Associate Judges shall be (1) Decisions of the Collector of Internal Revenue in cases involving disputed
appointed to hold office during good behavior, until they reach the age of seventy, or assessments, refunds of internal revenue taxes, fees or other charges, penalties
become incapacitated to discharge the duties of their office, unless sooner removed for imposed in relation thereto, or other matters arising under the National Internal Revenue
the same causes and in the same manner provided by law for members of the judiciary Code or other law or part of law administered by the Bureau of Internal Revenue;
of appellate rank.
(2) Decisions of the Commissioner of Customs in cases involving liability for customs
Section 2. Quorum; temporary vacancy. - Any two Judges of the Court of Tax Appeals duties, fees or other money charges; seizure, detention or release of property affected
shall constitute a quorum, and the concurrence of two judges shall be necessary to fines, forfeitures or other penalties imposed in relation thereto; or other matters arising
promulgate any decision thereof. In case of temporary vacancy, disability or under the Customs Law or other law or part of law administered by the Bureau of
disqualification, for any reason, of any of the judges of the said Court, the President may, Customs; and
upon the request of the Presiding Judge, designate any Judge of First Instance to act in
his place; and such Judge of First Instance shall be duly qualified to act as such. (3) Decisions of provincial or city Boards of Assessment Appeals in cases involving the
assessment and taxation of real property or other matters arising under the Assessment
Section 3. Clerk of court; appointment; qualification; compensation. - The Court of Tax Law, including rules and regulations relative thereto.
Appeals shall have the Clerk of Court who shall be appointed by the President with the
consent of the Commission on Appointments. No person shall be appointed Clerk of Section 8. Court of record; seal; proceedings. - The Court of Tax Appeals shall be a
Court unless he is duly authorized to practice law in the Philippines. The Clerk of Court court of record and shall have a seal which shall be judicially noticed. It shall prescribe
shall exercise the same powers and perform the same duties in regard to all matters the form of its writs and other processes. It shall have the power to promulgate rules and
within the court's jurisdiction, as are exercise and performed by clerks of Court of First regulations for the conduct of the business of the Court, and as may be needful for the
Instance, in so far of those powers and the performance of those duties the clerk shall uniformity of decisions within its jurisdiction as conferred by law, but such proceedings
be under the direction of the said court. The Clerk of Court shall receive a compensation shall not be governed strictly by technical rules of evidence.
of six thousand pesos per annum.
Section 9. Fees. - The Court shall fix reasonable fees for the filing of an appeal, for
Section 4. Other subordinate employees. - The Court of Tax Appeals shall appoint, in certified copies of any transcript of record, entry or other document, and for other
accordance with the Civil Service Law, rules and regulations, the necessary personnel authorized services rendered by the Court or its personnel.
to assist it in the performance of its duties. The said Court shall fix their salaries and
prescribe their duties. Section 10. Power to administer oaths; issue subpoena; punish for contempt. - The
Court shall have the power to administer oaths, receive evidence, summon witnesses
Section 5. Disqualifications. - No judge or other officer or employee of the Court of Tax by subpoena and require the production of papers or documents by subpoena duce
Appeals shall intervene, directly or indirectly, in the management or control of any private tecum, subject in all respects to the same restrictions and qualifications as apply in
enterprise which in any way may be affected by the functions of the Court. Judges of the judicial proceedings of a similar nature. The Court shall, in accordance with Rule sixty-
said Court shall be disqualified from sitting in any case on the same grounds provided
four for the Rules of Court, have the power to punish for contempt for the same causes, the certificate, and no leave shall be granted and no salary shall be paid without such
under the same procedure and with the same penalties provided therein. certificate.

Section 11. Who may appeal; effect of appeal. - Any person association or corporation Section 14. Effect of decision that tax is barred by statute of limitations. - If the
adversely affected by a decision or ruling of the Collector of Internal Revenue, the assessment or collection of any tax is barred by any statute of limitations, the decisions
Collector of Customs or any provincial or city Board of Assessment Appeals may file an of the Court that effect shall be considered as its decision that there is no deficiency in
appeal in the Court of Tax Appeals within thirty days after the receipt of such decision respect of such tax.
or ruling.
Section 15. Publicity of proceedings and publication of decisions. - All decisions of, and
No appeal taken by the Court of Appeals from the decision of the Collector of Internal all evidence received by the Court and its divisions, including transcript of stenographic
Revenue or the Collector of Customs shall suspend the payment, levy, distraint, and or reports of the hearings, shall be public records open to the inspection of the public,
sale of any property of the taxpayer for the satisfaction of his tax liability as provided by except that after the decision of the Court in any proceedings has become final the Court
existing law; Provided, however, That when in the opinion of the Court the collection by may, upon motion of the taxpayer or the Government permit the withdrawal, by the part
the Bureau of Internal Revenue or the Commissioner of Customs may jeopardize the entitled thereto of originals of books, documents and records, and or models, diagrams,
interest of the Government and/or the taxpayer the Court at any stage of the proceeding and other exhibits, introduced in evidence before the Court or any division; or the Court
may suspend the said collection and require the taxpayer either to deposit the amount may, on its own motion, make such other disposition thereof as it deems advisable. The
claimed or to file a surety bond for not more than double the amount with the Court; Court shall provide for the publication of its decisions in the Official Gazette in such form
and manner as may be best adopted for public information and use.
Section 12. Taking of evidence. - The Court may, upon proper motion on or its initiative,
direct that a case, or any issue thereof, be assigned to one of its members for the taking Section 16. Damages. - Where an appeal is found to be frivolous, or that proceedings
of evidence, when the determination of a question of fact arises upon motion or have been instituted merely for delay, the Court may assess damage against the
otherwise in any stage of the proceedings, or when the taking of an account is appellants in an amount not exceeding five hundred pesos, which shall be collected in
necessary, or when the determination of an issue of fact requires the examination of a the same manner as fines or other penalties authorized by law.
long account. The hearing before such member shall proceed in all respects as though
the same had been made before the Court. Section 17. Violation of penal law. - When, in the performance of its functions, it should
appear to the Court that a crime or other violation of law has been committed, or, that
Upon the recommendation of such hearing such member, he shall promptly submit to there are reasonable grounds to believe that any official, employee or private person is
the Court his report in writing, stating his findings and conclusions; and thereafter, the guilty of any crime, offense or other violation, the Court shall refer the matter to the
Court shall render its decisions on the case, adopting, modifying, or rejecting the report proper department, bureau or office for investigation or the institution of such criminal or
in whole or in part, as the case may be, or the Court may, in its discretion recommit it administrative action as the facts and circumstances of the case may warrant.
with instructions, or receive further evidence.
Section 18. Appeal to the Supreme Court. - No judicial proceeding against the
Section 13. Decision. - Cases brought before the Court shall be decided within thirty Government involving matters arising under the National Internal Revenue Code, the
days after the submission thereof for decision. Decisions of the Court shall be in writing, Customs Law or the Assessment Law shall be maintained, except as herein provided,
stating clearly and distinctly the facts and the law on which they are based, and signed until and unless an appeal has been previously filed with the Court of Tax Appeals and
by the judges concurring therein. The Court shall provide for the publication of its disposed of in accordance with the provisions of this Act.
decisions in the Official Gazette in such form and manner as may best be adopted for
public information and use. Any party adversely affected by any ruling, order or decision of the Court of tax Appeals
may appeal therefrom to the Supreme Court by filing with the said Court a notice of
As in the case of judicial officers under section one hundred twenty-nine of the appeal and with the Supreme Court a petition for review, within thirty days from the date
Administrative Code, the judges of the Court shall each certify on their applications for he receives notice of said ruling, order or decision. If, within the aforesaid period, he fails
leave, and upon salary vouchers presented by them for payment, or upon the payrolls to perfect his appeal, the said ruling, order or decision shall become final and conclusive
under which their salaries are paid, that all proceedings, petitions and motions which against him
have been submitted to the Court for determination or decision for a period of thirty days
or more have been determined or decided by the Court on or before the date of making If no decision is rendered by the Court within thirty days from the date a case is submitted
for decision, the party adversely affected by said ruling, order or decision may file with
said Court a notice of his intention to appeal to the Supreme Court, and if, within thirty
days from the filing of said notice of intention to appeal, no decision has as yet been Any law or part of law, or any executive order, rule or regulation or part thereon,
rendered by the Court, the aggrieved party may file directly with the Supreme Court an inconsistent with the provisions of this Act is hereby repealed.
appeal from said ruling, order or decision, notwithstanding the foregoing provisions of
this section. Section 22. Pending cases to be remanded to Court. - All cases involving disputed
assessment of Internal Revenue taxes or customs duties pending determination before
If any ruling, order or decision of the Court of Tax Appeals be adverse to the the Court of First Instance shall be certified and remanded by the respective clerk of
Government, the Collector of Internal Revenue, the Commissioner of Customs, or the court to the Court of Tax Appeals for final disposition thereof.
provincial or city Board of Assessment Appeals concerned may likewise file an appeal
therefrom to the Supreme Court in the manner and within the same period as above Section 23. Separability Clause. - If any clause, sentence, paragraph or part of this act
prescribed for private parties. shall be adjudged by any court of competent jurisdiction to be invalid, such judgment
shall not affect, impair or invalidate the remainder of this Act, but shall confined in its
Any proceeding directly affecting any ruling, order or decision of the Court of Tax operations to the clause, sentence, paragraph or part thereof directly involved in the
Appeals shall have preference over all other civil proceedings except habeas corpus, controversy.
workmen's compensation and election cases.
Section 24. This Act shall take effect upon its approval.
Section 19. Review by certiorari. - Any ruling, order or decision of the Court of Tax
Appeals may likewise be reviewed by the Supreme Court upon a writ of certiorari in Approved: June 16, 1954
proper cases. Proceedings in the Supreme Court upon a writ of certiorari or a petition
for review, as the case may be, shall be in accordance with the provisions of the Rules
of Court or such rules as the Supreme Court may prescribe.

Section 20. Appropriation. - The sum of seventy-thousand pesos is hereby appropriated

Section 21. General provisions. - Whenever the words "Board of Tax Appeals" are used
in Commonwealth Act Numbered Four hundred and seventy, otherwise known as the
Assessment Law, or in other laws, rules and regulations relative thereto, the same shall
read "Board of Assessment Appeals."

The Central Board of Tax Appeals created under section two of Commonwealth Act
Numbered Five hundred and thirty is hereby abolished.

Executive Order Numbered Four hundred and one-A, dated the fifth of January, nineteen
hundred and fifty- one, is repealed and the Board of Tax Appeals created therein,
abolished: Provided, however, That all cases heretofore decided by the said Board of
Tax Appeals and thence appealed to the Supreme Court pursuant to Executive Order
Numbered Four hundred one-A shall be decided by the Supreme Court on the merits to
all intents and purposes as if said Executive Order has been duly enacted by the
Congress: And, Provided, further, That all cases now pending in the said Board of Tax
Appeals shall be transferred to the Court of Tax Appeals and shall be heard and decided
by the latter to all intents and purposes as if they had been originally filed therein.
Republic Act No. 9282 March 30 2004
"Four (4) Justices shall constitute a quorum for sessions en banc and two (2) Justices
AN ACT EXPANDING THE JURISDICTION OF THE COURT OF TAX APPEALS for sessions of a Division: Provided, That when the required quorum cannot be
(CTA), ELEVATING ITS RANK TO THE LEVEL OF A COLLEGIATE COURT WITH constituted due to any vacancy, disqualification, inhibition, disability, or any other lawful
SPECIAL JURISDICTION AND ENLARGING ITS MEMBERSHIP, AMENDING FOR cause, the Presiding Justice shall designate any Justice of other Divisions of the Court
THE PURPOSE CERTAIN SECTIONS OR REPUBLIC ACT NO. 1125, AS AMENDED, to sit temporarily therein.
OTHERWISE KNOWN AS THE LAW CREATING THE COURT OF TAX APPEALS,
AND FOR OTHER PURPOSES "The affirmative votes of four (4) members of the Court en banc or two (2) members of
a Division, as the case may be, shall be necessary for the rendition of a decision or
Be it enacted by the Senate and House of Representatives of the Philippine Congress resolution."
Assembled:
Section 3. Section 3 of the same Act is hereby amended to read as follows:
Section 1. Section 1 of Republic Act No. 1125, as amended is hereby further amended
to read as follows: "SEC. 3. Clerk of Court; Division Clerks of Court; Appointment; Qualification;
Compensation. - The CTA shall have a Clerk of Court and three (3) Division Clerks of
"SECTION 1. Court; Justices; Qualifications; Salary; Tenure. - There is hereby created Court who shall be appointed by the Supreme Court. No person shall be appointed Clerk
a Court of Tax Appeals (CTA) which shall be of the same level as the Court of Appeals, of Court or Division Clerk of Court unless he is duly authorized to practice law in the
possessing all the inherent powers of a Court of Justice, and shall consist of a Presiding Philippines. The Clerk of Court and Division Clerks of Court shall exercise the same
Justice and five (5) Associate Justices. The incumbent Presiding Judge and Associate powers and perform the same duties in regard to all matters within the Court's
Judges shall continue in office and bear the new titles of Presiding Justice and Associate jurisdiction, as are exercised and performed by the Clerk of Court and Division Clerks of
Justices. The Presiding Justice and the most Senior Associate Justice shall serve as Court of the Court of Appeals, in so far as the same may be applicable or analogous;
chairmen of the two (2) Divisions. The additional three (3) Justices and succeeding and in the exercise of those powers and the performance of those duties they shall be
members of the Court shall be appointed by the President upon nomination by the under the direction of the Court. The Clerk of Court and the Division Clerks of Court shall
Judicial and Bar Council. The Presiding Justice shall be so designated in his have the same rank, privileges, salary, emoluments, retirement and other benefits as
appointment, and the Associate Justices shall have precedence according to the date those provided for the Clerk of Court and Division Clerks of Court of the Court of
of their respective appointments, or when the appointments of two (2) or more of them Appeals, respectively.'
shall bear the same date, according to the order in which their appointments were issued
by the President. They shall have the same qualifications, rank, category, salary, Section 4. Section 4 of the same Act is hereby amended to read as follows:
emoluments and other privileges, be subject to the same inhibitions and
disqualifications, and enjoy the same retirements and other benefits as those provided "SEC. 4. Other Subordinate Employees. - The Supreme Court shall appoint all officials
for under existing laws for the Presiding Justice and Associate Justices of the Court of and employees of the CTA, in accordance with the Civil Service Law. The Supreme
Appeals. Court shall fix their salaries and prescribe their duties."

"Whenever the salaries of the Presiding Justice and the Associate Justices of the Court Section 5. Section 5 of the same Act is hereby amended to read as follows:
of Appeals are increased, such increases in salaries shall be deemed correspondingly
extended to and enjoyed by the Presiding Justice and Associate Justices of the CTA. "SEC. 5. Disqualifications. - No Justice or other officer or employee of the CTA shall
intervene, directly or indirectly, in the management or control of any private enterprise
"The Presiding Justice and Associate Justices shall hold office during good behavior, which in any way may be affected by the functions of the Court. Justices of the Court
until they reach the age of seventy (70), or become incapacitated to discharge the duties shall be disqualified from sitting in any case on the same grounds provided under Rule
of their office, unless sooner removed for the same causes and in the same manner one hundred thirty-seven of the Rules of Court for the disqualification of judicial officers.
provided by law for members of the judiciary of equivalent rank." No person who has once served in the Court in a permanent capacity, either as
Presiding Justice or as Associate Justice thereof, shall be qualified to practice as
Section 2. Section 2 of the same Act is hereby amended to read as follows: counsel before the Court for a period of one (1) year from his retirement or resignation."

"SEC. 2. Sitting En Banc or Division; Quorum; Proceedings. - The CTA may sit en banc Section 6. Section 6 of the same Act is hereby amended to read as follows:
or in two (2) Divisions, each Division consisting of three (3) Justices.
"SEC. 6. Place of Office. - The CTA shall have its principal office in Metro Manila and
shall hold hearings at such time and place as it may, by order in writing, designate." "1. Exclusive original jurisdiction over all criminal offenses arising from violations of the
National Internal Revenue Code or Tariff and Customs Code and other laws
Section 7. Section 7 of the same Act is hereby amended to read as follows: administered by the Bureau of Internal Revenue or the Bureau of Customs: Provided,
however, That offenses or felonies mentioned in this paragraph where the principal
"Sec. 7. Jurisdiction. - The CTA shall exercise: amount o taxes and fees, exclusive of charges and penalties, claimed is less than One
million pesos (P1,000,000.00) or where there is no specified amount claimed shall be
"a. Exclusive appellate jurisdiction to review by appeal, as herein provided: tried by the regular Courts and the jurisdiction of the CTA shall be appellate. Any
provision of law or the Rules of Court to the contrary notwithstanding, the criminal action
"1. Decisions of the Commissioner of Internal Revenue in cases involving disputed and the corresponding civil action for the recovery of civil liability for taxes and penalties
assessments, refunds of internal revenue taxes, fees or other charges, penalties in shall at all times be simultaneously instituted with, and jointly determined in the same
relation thereto, or other matters arising under the National Internal Revenue or other proceeding by the CTA, the filing of the criminal action being deemed to necessarily
laws administered by the Bureau of Internal Revenue; carry with it the filing of the civil action, and no right to reserve the filling of such civil
action separately from the criminal action will be recognized.
"2. Inaction by the Commissioner of Internal Revenue in cases involving disputed
assessments, refunds of internal revenue taxes, fees or other charges, penalties in "2. Exclusive appellate jurisdiction in criminal offenses:
relations thereto, or other matters arising under the National Internal Revenue Code or
other laws administered by the Bureau of Internal Revenue, where the National Internal "a. Over appeals from the judgments, resolutions or orders of the Regional Trial Courts
Revenue Code provides a specific period of action, in which case the inaction shall be in tax cases originally decided by them, in their respected territorial jurisdiction.
deemed a denial;
"b. Over petitions for review of the judgments, resolutions or orders of the Regional Trial
"3. Decisions, orders or resolutions of the Regional Trial Courts in local tax cases Courts in the exercise of their appellate jurisdiction over tax cases originally decided by
originally decided or resolved by them in the exercise of their original or appellate the Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts
jurisdiction; in their respective jurisdiction.

"4. Decisions of the Commissioner of Customs in cases involving liability for customs "c. Jurisdiction over tax collection cases as herein provided:
duties, fees or other money charges, seizure, detention or release of property affected,
fines, forfeitures or other penalties in relation thereto, or other matters arising under the "1. Exclusive original jurisdiction in tax collection cases involving final and executory
Customs Law or other laws administered by the Bureau of Customs; assessments for taxes, fees, charges and penalties: Provided, however, That collection
cases where the principal amount of taxes and fees, exclusive of charges and penalties,
"5. Decisions of the Central Board of Assessment Appeals in the exercise of its appellate claimed is less than One million pesos (P1,000,000.00) shall be tried by the proper
jurisdiction over cases involving the assessment and taxation of real property originally Municipal Trial Court, Metropolitan Trial Court and Regional Trial Court.
decided by the provincial or city board of assessment appeals;
"2. Exclusive appellate jurisdiction in tax collection cases:
"6. Decisions of the Secretary of Finance on customs cases elevated to him
automatically for review from decisions of the Commissioner of Customs which are "a. Over appeals from the judgments, resolutions or orders of the Regional Trial Courts
adverse to the Government under Section 2315 of the Tariff and Customs Code; in tax collection cases originally decided by them, in their respective territorial
jurisdiction.
"7. Decisions of the Secretary of Trade and Industry, in the case of nonagricultural
product, commodity or article, and the Secretary of Agriculture in the case of agricultural "b. Over petitions for review of the judgments, resolutions or orders of the Regional Trial
product, commodity or article, involving dumping and countervailing duties under Courts in the Exercise of their appellate jurisdiction over tax collection cases originally
Section 301 and 302, respectively, of the Tariff and Customs Code, and safeguard decided by the Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit
measures under Republic Act No. 8800, where either party may appeal the decision to Trial Courts, in their respective jurisdiction."
impose or not to impose said duties.
Section 8. Section 10 of the same Act is hereby amended to read as follows:
"b. Jurisdiction over cases involving criminal offenses as herein provided:
"SEC. 10. Power to Administer Oaths; Issue Subpoena; Punish for Contempt. - The "In criminal and collection cases covered respectively by Section 7(b) and (c) of this Act,
Court shall have the power to administer oaths, receive evidence, summon witnesses the Government may directly file the said cases with the CTA covering amounts within
by subpoena duces tecum, subject in all respects to the same restrictions and its exclusive and original jurisdiction."
qualifications as applied in judicial proceedings of a similar nature. The Court shall, in
accordance with Rule seventy-one of the Rules of Court, have the power to punish for Section 10. Section 13 of the same Act is hereby amended to read as follows:
contempt for the same causes, under the same procedure and with the same penalties
provided therein." "SEC. 13. Decision, Maximum Period for Termination of Cases. - Cases brought before
the Court shall be decided in accordance with Section 15, paragraph (1), Article VIII
Section 9. Section 11 of the same Act is hereby amended to read as follows: (Judicial Department) of the 1987 Constitution. Decisions of the Court shall be in writing,
stating clearly and distinctly the facts and the law on which they are based, and signed
"SEC. 11. Who May Appeal; Mode of Appeal; Effect of Appeal. - Any party adversely by the Justices concurring therein. The Court shall provide for the publication of its
affected by a decision, ruling or inaction of the Commissioner of Internal Revenue, the decision in the Official Gazette in such form and manner as may best be adopted for
Commissioner of Customs, the Secretary of Finance, the Secretary of Trade and public information and use.
Industry or the Secretary of Agriculture or the Central Board of Assessment Appeals or
the Regional Trial Courts may file an appeal with the CTA within thirty (30) days after "The Justices of the Court shall each certify on their applications for leave, and upon
the receipt of such decision or ruling or after the expiration of the period fixed by law for salary vouchers presented by them for payment, or upon the payrolls under which their
action as referred to in Section 7(a)(2) herein. salaries are paid, that all proceedings, petitions and motions which have been submitted
to the Court for determination or decision for a period required by the law or the
"Appeal shall be made by filing a petition for review under a procedure analogous to that Constitution, as the case may be, have been determined or decided by the Court on or
provided for under Rule 42 of the 1997 Rules of Civil Procedure with the CTA within before the date of making the certificate, and no leave shall be granted and no salary
thirty (30) days from the receipt of the decision or ruling or in the case of inaction as shall be paid without such certificate."
herein provided, from the expiration of the period fixed by law to act thereon. A Division
of the CTA shall hear the appeal: Provided, however, That with respect to decisions or Section 11. Section 18 of the same Act is hereby amended as follows:
rulings of the Central Board of Assessment Appeals and the Regional Trial Court in the
exercise of its appellate jurisdiction appeal shall be made by filing a petition for review "SEC. 18. Appeal to the Court of Tax Appeals En Banc. - No civil proceeding involving
under a procedure analogous to that provided for under rule 43 of the 1997 Rules of matter arising under the National Internal Revenue Code, the Tariff and Customs Code
Civil Procedure with the CTA, which shall hear the case en banc. or the Local Government Code shall be maintained, except as herein provided, until and
unless an appeal has been previously filed with the CTA and disposed of in accordance
"All other cases involving rulings, orders or decisions filed with the CTA as provided for with the provisions of this Act.
in Section 7 shall be raffled to its Divisions. A party adversely affected by a ruling, order
or decision of a Division of the CTA may file a motion for reconsideration of new trial "A party adversely affected by a resolution of a Division of the CTA on a motion for
before the same Division of the CTA within fifteens (15) days from notice thereof: reconsideration or new trial, may file a petition for review with the CTA en banc."
Provide, however, That in criminal cases, the general rule applicable in regular Courts
on matters of prosecution and appeal shall likewise apply. "SEC. 19. Review by Certiorari. - A party adversely affected by a decision or ruling of
the CTA en banc may file with the Supreme Court a verified petition for review on
"No appeal taken to the CTA from the decision of the Commissioner of Internal Revenue certiorari pursuant to Rule 45 of the 1997 Rules of Civil Procedure."
or the Commissioner of Customs or the Regional Trial Court, provincial, city or municipal
treasurer or the Secretary of Finance, the Secretary of Trade and Industry and Secretary Section 13. Distraint of Personal Property and/or Levy on Real Property. - Upon the
of Agriculture, as the case may be shall suspend the payment, levy, distraint, and/or sale issuance of any ruling, order or decision by the CTA favorable to the national
of any property of the taxpayer for the satisfaction of his tax liability as provided by government, the CTA shall issue an order authorizing the Bureau of Internal Revenue,
existing law: Provided, however, That when in the opinion of the Court the collection by through the Commissioner to seize and distraint any goods, chattels, or effects, and the
the aforementioned government agencies may jeopardize the interest of the personal property, including stocks and other securities, debts, credits, bank accounts,
Government and/or the taxpayer the Court any stage of the proceeding may suspend and interests in and rights to personal property and/or levy the real property of such
the said collection and require the taxpayer either to deposit the amount claimed or to persons in sufficient quantity to satisfy the tax or charge together with any increment
file a surety bond for not more than double the amount with the Court. thereto incident to delinquency. This remedy shall not be exclusive and shall not
preclude the Court from availing of other means under the Rules of Court.
Section 14. Retention of Personnel; Security of Tenure; Upgrading of Positions and Approved: March 30 2004
Salaries. - All existing permanent personnel of the CTA shall not be adversely affected
by this Act. They shall continue in office and shall not be removed or separated from the GLORIA MACAPAGAL-ARROYO
service except for cause as provided for by existing laws. Further, the present positions President of the Philippines
and salaries of personnel shall be upgraded to the level of their counterparts in the Court
of Appeals.

Section 15. Transitory Provisions. - In consonance with the above provision, the
incumbent Presiding Judge and Associate Judges shall comprise a Division pending the
constitution of the entire Court.

Section 16. Appropriations. - The amount necessary to carry out the provisions of this
Act shall be included in the General Appropriations Act of the year following its
enactment into law and thereafter.

Section 17. Repealing Clause. - All laws, executive orders, executive issuances or letter
of instructions, or any part thereof, inconsistent with or contrary to the provisions of this
Act are hereby deemed repealed, amended or modified accordingly.

Section 18. Separability Clause. - If for any reason, any section or provision of this Act
shall be declared unconstitutional or invalid, the other parts thereof not affected thereby
shall remain valid.

Section 19. Effectivity Clause - This Act shall take effect after fifteen (15) days following
its publication in at least (2) newspapers of general circulation.

Approved,

FRANKLIN DRILON
President of the Senate

JOSE DE VENECIA JR.

This Act which is a consolidation of Senate Bill No. 2712 and House Bill No. 6673 was
finally passed by the Senate and the House of Representatives on December 8, 2003
and February 2, 2004, respectively.

OSCAR G. YABES
Secretary of Senate

ROBERTO P. NAZARENO
Secretary General
House of Represenatives