Commissioner of Internal Revenue v. Nippon Express Philippines Corporation

Summary

This case clarifies the jurisdictional boundaries within the Court of Tax Appeals (CTA). The Commissioner of Internal Revenue (CIR) challenged an interlocutory order of a CTA Division (allowing ex-parte evidence presentation due to the CIR's failure to file a hard copy of its answer) by filing a Petition for Certiorari under Rule 65 with the CTA En Banc. The CTA En Banc dismissed the petition, claiming it lacked jurisdiction over interlocutory orders. The Supreme Court affirmed the dismissal, establishing the landmark principle that the CTA En Banc does not possess supervisory or certiorari jurisdiction over its own Divisions. Because the CTA is a single collegial body, there is no hierarchical relationship between the En Banc and its Divisions that would allow for the issuance of a writ of certiorari. The Court held that while the En Banc has appellate jurisdiction over final judgments, any petition for certiorari assailing interlocutory orders of a CTA Division must be filed directly with the Supreme Court.