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BDO etc. vs. Republic of the Philippines [RESOLUTION]

BANCO DE ORO, BANK OF COMMERCE, CHINA BANKING CORPORATION, METROPOLITAN BANK & TRUST COMPANY, PHILIPPINE BANK OF COMMUNICATIONS, PHILIPPINE NATIONAL BANK, PHILIPPINE VETERANS BANK, AND PLANTERS DEVELOPMENT BANK, Petitioners, RIZAL COMMERCIAL BANKING CORPORATION AND RCBC CAPITAL CORPORATION, Petitioners-Intervenors, CAUCUS OF DEVELOPMENT NGO NETWORKS, Petitioner-Intervenor, vs. REPUBLIC OF THE PHILIPPINES, COMMISSIONER OF INTERNAL REVENUE, BUREAU OF INTERNAL REVENUE, SECRETARY OF FINANCE, DEPARTMENT OF FINANCE, THE NATIONAL TREASURER, AND BUREAU OF TREASURY, Respondents. Present: SERENO, C.J., CARPIO,* VELASCO, JR., LEONARDO-DE CASTRO, BRION** PERALTA, BERSAMIN, DEL CASTILLO, PEREZ, MENDOZA, REYES, PERLAS-BERNABE, LEONEN, JARDELEZA,*** and CAGUIOA, JJ.

G.R. No. 198756 (Resolution) | 2016-08-16

EN BANC
RESOLUTION
 
LEONEN, J.:
 
This resolves separate motions for reconsideration and clarification filed by the Office of the Solicitor General1 and petitioners-intervenors Rizal Commercial Banking Corporation and RCBC Capital Corporation2 of our Decision dated January 13, 2015, which:
 
(1) granted the Petition and Petitions-in-Intervention and nullified Bureau of Internal Revenue (BIR) Ruling Nos. 370-2011 and DA 378-2011; and
 
(2) reprimanded the Bureau of Treasury for its continued retention of the amount corresponding to the 20% final withholding tax that it withheld on October 18, 2011, and ordered it to...