Commercial and Taxation Laws › Taxation Law › Tax Remedies › Judicial Remedies
a. Jurisdiction of the Court of Tax Appeals (CTA)
Court of Tax Appeals (CTA)
- Exclusive Original and Appellate Jurisdiction Over Civil Cases
- Exclusive Original and Appellate Jurisdiction Over Criminal Cases
Laws Governing the Court of Tax Appeals
- RA 1125, enacted June 16, 1954, created the Court of Tax Appeals (CTA)1
- RA 9282, enacted March 30, 2004, amended RA 11252
- RA 9503, enacted June 12, 2008, further amended RA 11253
- RA 9282 expanded the jurisdiction of the CTA and elevated it to the level of the Court of Appeals
- RA 9282 also provided, among others, that appeals from the decision of the CTA En Banc shall now be made before the Supreme Court
- RA 9503 provided for the increase in the number of the CTA Justices from 6 to 9, increased the number of Divisions from 2 to 3, with each division composed of 3 justices
Features of the CTA
- Regular Court, vested with exclusive original or appellate jurisdiction over specified tax and customs cases, as provided by law (R.A. No. 1125, as amended, Secs. 7 and 11; CIR v. CA, G.R. No. 104151)4
- A highly specialized body specifically created for the purpose of reviewing tax cases. (Philippine Refining Company v. Court of Appeals, G.R. No. 118794, 8 May 1996)5
- A Court of special or limited jurisdiction, and as such, it can only take cognizance of such matter clearly within its jurisdiction (Ker v. CTA, G.R. No. L-12396)6
- Proceedings are judicial in nature, although they are not governed strictly by technical rules of evidence (R.A. No. 1125, as amended, Sec. 8)7
Laws Governing the Court of Tax Appeals
- RA 1125, enacted June 16, 1954, created the Court of Tax Appeals (CTA)8
- RA 9282, enacted March 30, 2004, amended RA 11259
- RA 9503, enacted June 12, 2008, further amended RA 112510
- RA 9282 expanded the jurisdiction of the CTA and elevated it to the level of the Court of Appeals
- RA 9282 also provided, among others, that appeals from the decision of the CTA En Banc shall now be made before the Supreme Court
- RA 9503 provided for the increase in the number of the CTA Justices from 6 to 9, increased the number of Divisions from 2 to 3, with each division composed of 3 justices
Features of the CTA
- Regular Court, vested with exclusive original or appellate jurisdiction over specified tax and customs cases, as provided by law (R.A. No. 1125, as amended by R.A. No. 9282, Secs. 7 and 11) (CIR v. CA, G.R. No. 104151)11
- A highly specialized body specifically created for the purpose of reviewing tax cases. (Philippine Refining Company v. Court of Appeals, G.R. No. 118794, 8 May 1996)12
- A Court of special or limited jurisdiction, and as such, it can only take cognizance of such matter clearly within its jurisdiction (Ker v. CTA, G.R. No. L-12396)13
- Proceedings are judicial in nature, although they are not governed strictly by technical rules of evidence (R.A. No. 1125, as amended, Sec. 8)14
Authorities
- CIR v. CA, G.R. No. 104151
- KER and COMPANY, LTD. v. CTA, G.R. No. L-12396, 31 January 1962
- Philippine Refining Company v. Court of Appeals, G.R. No. 118794, 8 May 1996
- R.A. No. 1125, Sec. 8
- RA 1125
- RA 1125, Sec. 8
- RA 9282
- RA 9503