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Commissioner of Internal Revenue vs. Philippine National Bank

COMMISSIONER OF INTERNAL REVENUE, Petitioner, versus PHILIPPINE NATIONAL BANK, Respondent.

G.R. No. 161997 | 2005-10-25

D E C I S I O N 


GARCIA, J.: 

Thru this appeal by way of a petition for review on certiorari under Rule 45 of the Rules of Court, petitioner Commissioner of Internal Revenue seeks to set aside the Decision dated October 14, 2003[1] of the Court of Appeals (CA) in CA-G.R. SP No. 76488 and its Resolution dated January 26, 2004[2] denying petitioner's motion for reconsideration. 

The petition is cast against the following factual setting: 

In early April 1991, respondent Philippine National Bank (PNB) issued to the Bureau of Internal Revenue (BIR) PNB Cashier's Check No. 109435 for P180,000,000.00. The check represented...