Case Rule of Procedure

1. Decisions of the Commissioner of Same as Court of Appeals (Rule 42,

Simplified Court of Tax Appeals (CTA) Rules of Procedure Internal Revenue (CIR) [including
his inaction]; Customs
Commissioner; and Departments
of Finance, Trade and Industry,
EN BANC and Agriculture
2. RTCs deciding in their original
jurisdiction (criminal, local tax
cases, or tax collection cases)
#3 DIVISION #4
3. RTCs deciding in their appellate
jurisdiction (criminal, local tax
#1 #2 cases, or tax collection cases);
and Central Board of Assessment
Appeals (CBAA)
Rules of Court), unless otherwise
provided by the Court of Tax
Appeals Rules of Procedure;
Pleading: Petition for Review;
Caption: Petitioner v. Respondent
For criminal, governing rule is Rule
124 of Rules of Court; Notice of
Appeal is needed within 15 days
from decision/resolution appealed
from.
For tax collection cases, same as
Court of Appeals (Rule 42, Rules of
Court). Caption, however, is still the
original plus Appellant v. Appellee.
Rule 43, Rules of Court

4. Criminal: violation of Tax or

Customs Codes or any law In these cases, CTA is exercising its
administered by BIR or Customs exclusive original jurisdiction.
where principal amount involved Nevertheless, in both criminal and
is over Php1,000,000 civil cases, the procedure of trial as
Legend: observed in regular courts are
Civil: Tax collection cases where likewise applied.
 Rectangle with arrows – Cases wherein CTA exercises its exclusive appellate
principal amount involved is over
jurisdiction. The arrows represent to where these cases are cognizable (either in Php1,000,000
the CTA En Banc or CTA Division).
 Oval with line – Cases wherein CTA exercises its exclusive original jurisdiction.
The line connects to where these cases are cognizable (that is, CTA Division).
 The numbers appearing both in the rectangles and oval correspond to the description in the table.

References: A.M. No. 05-11-07-CTA, November 22, 2005, as amended by A.M. No. 05-11-07-CTA, September 16, 2008, and Republic Act No. 9282.
Prepared By: Ramon T. Conducto II, October 9, 2014.