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COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. SILICON PHILIPPINES, INC. (FORMERLY INTEL PHILIPPINES MANUFACTURING, INC.), RESPONDENT.

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. SILICON PHILIPPINES, INC. (FORMERLY INTEL PHILIPPINES MANUFACTURING, INC.), RESPONDENT.

G.R. No. 169778 | 2014-03-12

SECOND DIVISION
 
D E C I S I O N
 
PEREZ, J.:
 
To obviate the possibility that its decision may be rendered void, the Court can, by its own initiative, rule on the question of jurisdiction, although not raised by the parties.[1]  As a corollary thereto, to inquire into the existence of jurisdiction over the subject matter is the primary concern of a court, for thereon would depend the validity of its entire proceedings.[2]

Before the Court is a Petition for Review on Certiorari seeking to reverse and set aside the 16 September 2005 Decision[3] of the Court of Appeals (CA) in CA-G.R. SP No. 80886 granting...