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NATIONAL POWER CORPORATION, PETITIONER, VS. MUNICIPAL GOVERNMENT OF NAVOTAS, SANGGUNIANG BAYAN OF NAVOTAS AND MANUEL T. ENRIQUEZ, IN HIS CAPACITY AS MUNICIPAL TREASURER OF NAVOTAS, RESPONDENTS.

NATIONAL POWER CORPORATION, PETITIONER, VS. MUNICIPAL GOVERNMENT OF NAVOTAS, SANGGUNIANG BAYAN OF NAVOTAS AND MANUEL T. ENRIQUEZ, IN HIS CAPACITY AS MUNICIPAL TREASURER OF NAVOTAS, RESPONDENTS.

G.R. No. 192300 | 2014-11-24

THIRD DIVISION
 
D E C I S I O N

PERALTA, J.:

Before us is a Petition for Review on Certiorari under Rule 45 of the Rules of Court seeking to reverse and set aside the Decisiondated March 1, 2010 and Resolution2 dated May 6, 2010 of the Court of Tax Appeals (CTA)En Banc in E.B. No. 461.
 
The facts, as found by the CTA En Banc, are as follows:

Petitioner National Power Corporation (NPC) is a government-owned and controlled corporation organized and existing under and by virtue of Republic Act (RA) No. 6395, as amended, with principal office address at NPC Office Building Complex, corner Quezon Avenue and BIR Road, East...