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Department of Energy vs. CTA [DISSENTING OPINION DIMAAMPAO, J.]

THE DEPARTMENT OF ENERGY, PETITIONER, VS. COURT OF TAX APPEALS, RESPONDENT.

G.R. No. 260912 | 2022-08-17

DISSENTING OPINION

DIMAAMPAO, J.:

At the pith of this controversy lies the seemingly innocuous question: does the Court of Tax Appeals (CTA) have exclusive appellate jurisdiction over tax controversies involving government agencies and offices?

The ponencia answers this in the negative based on a straight application of the Court's doctrine in Power Sector Assets and Liabilities Management Corporation (PSALM) v. Commissioner of Internal Revenue.[1] The ponencia clarifies that the pronouncement in PSALM did not limit the application of the provisions of Presidential Decree (PD) No. 242 to instances where there...