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