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An Overview of the Expanded Court of Tax Appeals

Anthony Mark A. Gutierrez*


Introduction
Republic Act (R.A.) No. 9282, which took effect on April 23, 2004, amended
several key provisions of R.A. No. 1125 (the law creating the Court of Tax Appeals
or CTA). It expanded the CTAs jurisdiction to include, among others, tax
collection cases, local and real property taxes, and criminal cases involving
violations of tax and customs cases. The law also upgraded the CTAs rank to that
of the Court of Appeals and increased the number of magistrates.
The primary objective of Congress in expanding the CTAs jurisdiction is to curb
delays in the disposition of cases for the collection of internal revenue, local and
real property taxes, which have remained unattended in the regular courts in view
of their clogged dockets. Vesting the CTA with jurisdiction over both the civil and
criminal aspects of tax cases not only could improve the efficiency of the system,
but also enhance and maximize the development of judicial precedence on tax
matters. Some policy makers and experts see this as vital to effective tax
administration. Furthermore, the expansion of the CTAs jurisdiction is recognition
of that courts expertise in the field of taxation.
Upgrading the CTAs rank to one equal to that of the Court of Appeals, on the other
hand, is expected to lessen divisive rulings on tax matters because the appeal may
now be made only to the CTA en banc instead of the Court of Appeals with its
several divisions. Decisions of the CTA en banc may now be appealed directly to
the Supreme Court on questions of law.
The increase in the number of magistrates is intended to complement the
anticipated increase in caseload.
The amendments as a whole are also aimed at addressing problems of tax evasion
and smuggling because a single tax court can be expected to more properly
coordinate with revenue collection agencies in their efforts to curb these problems.1
This is not the first time that Congress has attempted to expand the CTAs
jurisdiction. The Eleventh Congress passed a measure similar to R.A. No. 9282
which was vetoed by the President not because of lack of merit but because the
Supreme Courts concurrence was not secured pursuant to the 1987 Constitution,
Article VI, section 30.2
Legislative History
Prior to the CTAs creation, a Board of Tax Appeals (BTA) was created pursuant
to E.O. No. 401-A. The BTA was tasked with hearing and deciding appeals from
decisions of the Collector of Internal Revenue in cases arising from internal
revenue, customs and assessment laws. However, the BTAs power to hear and
decide such cases was nullified by the Supreme Court on the ground that regular
courts cannot be deprived of their jurisdiction by mere executive fiat without
authority from Congress.3

The CTA was established in 1954 pursuant to R.A. No. 1125 for the main purpose
of creating a court having exclusive appellate jurisdiction over disputed tax
assessments and transferring to its jurisdiction all cases involving assessments
previously cognizable by courts of first instance.4
When it was created, the CTA originally exercised appellate jurisdiction over the
following cases: (i) decisions of the Commissioner of Internal Revenue (CIR) in
cases involving disputed assessments, refunds of internal taxes, fees or other
charges, penalties imposed in relation thereto, or other matters arising under the
National Internal Revenue Code (the Tax Code) or other law or part of law
administered by the Bureau of Internal Revenue (BIR); (ii) decisions of the
Commissioner of Customs in cases involving liability for customs duties, fees or
other money charges; seizure, detention or release of property affected; fines,
forfeitures or other penalties imposed in relation thereto; or other matters arising
under the Customs Law of other law or part of law administered by the Bureau of
Customs (BOC); and (iii) decisions of provincial or city Boards of Assessment
Appeals (BAA) in cases involving the assessment and taxation of real property
or other matters arising under the Assessment Law, including all rules and
regulations relative thereto.5
The CTAs jurisdiction over decisions of provincial or city BAAs was subsequently
transferred to the Central Board of Assessment Appeals (CBAA) pursuant to the
Real Property Tax Code, and had continued to remain with the CBAA with the
passage of the Local Government Code of 1991.6
The Safeguard Measures Act of 2000 expanded the CTAs appellate jurisdiction to
include decisions of the Secretary of Trade and Industry (in the case of nonagricultural products, commodities, or articles) and the Secretary of Agriculture (in
the case of agricultural products, commodities, or articles) involving dumping and
countervailing duties under section 301 and 302 of the Tariff and Customs Code
and safeguard measures.7
The CTA and its Justices
The CTA originally consisted of a Presiding Judge and two Associate Judges. The
Presiding Judge had the same qualifications, rank, category and privileges as the
Presiding Judge of the Court of Industrial Relations (the predecessor of the
National Labor Relations Commission), while the Associate Judges had the same
qualifications, rank, category and privileges as members of the Court of Industrial
Relations.8
With the passage of R.A. No. 9282, the CTA is now of the same level as the Court
of Appeals and now consists of a Presiding Justice and five Associate Justices.9
The incumbent Presiding Judge and Associate Judges will continue in office and
bear the new titles of Presiding Justice and Associate Justice. The Presiding Justice
and the most Senior Associate Justice will serve as chairman of two Divisions. 10
These provisions are necessary so as not to undermine the security of tenure
enjoyed by the incumbent Presiding Judge and Associate Judges.11

The President will appoint the additional three Justices and succeeding members of
the CTA, upon nomination by the Judicial and Bar Council. The Presiding Justice
will be so designated on his appointment and the Associate Justices will have
precedence according to the date of their respective appointments, or, when the
appointments of two or more of them bears the same date, according to the order in
which the appointments were issued by the President.12
The Justices will have the same qualification, rank, category, salary, emoluments
and other privileges, be subject to the same inhibitions and disqualifications, and
enjoy the same retirements and other benefits as those provided for under existing
laws for the Presiding Justice and Associate of the Court of Appeals.13
The Justices are disqualified from intervening, directly or indirectly, in the
management or control of any private enterprise, which in any way may be
affected by the functions of the CTA. They are likewise disqualified from sitting in
any case on the same grounds provided under Rule 137 of the Rules of Court (the
Rules) for the disqualification of judicial officers.14
The Justices will hold office during good behavior, until they reach the age of 70,
or become incapacitated to discharge the duties of their office, unless sooner
removed for the same causes and in the same manner provided by law for members
of the judiciary of equivalent rank.15 They are disqualified to act as counsel before
the CTA for a period of one year from his retirement or resignation.16
The CTA en banc and its Divisions
Four Justices will constitute a quorum for sessions en banc. The affirmative votes
of the same number of Justices will be necessary for the rendition of a decision or
resolution.
Two Justices will constitute a quorum for sessions of a Division. The affirmative
votes of the same number of Justices shall be necessary for the rendition of a
decision or resolution. However, when the required quorum in a Division cannot be
constituted due to any vacancy, disqualification inhibition, disability, or any other
lawful cause, the Presiding Justice can designate any Justice of other Division of
the Court to sit temporarily therein.
Expanded Jurisdiction of the CTA
National Internal Revenue Cases The CTA has maintained its appellate
jurisdiction to review by appeal decisions of the CIR in cases involving disputed
assessments, refunds of internal revenue taxes, fees, other charges, penalties
thereto, or other matters arising under the Tax Code or other laws administered by
the BIR.17
However, the CIRs inaction in cases involving disputed assessments, refunds of
internal revenue taxes, fees or other charges, penalties in relations thereto, or other
matters arising under the Tax Code or other laws administered by the BIR, where
the Tax Code provides a specific period of action, is now expressly deemed as a
denial which may be appealed to the CTA.18 This amendment will put in issue the
continued applicability of the ruling in Lascona v. CIR (CTA Case No. 5777,

January 4, 2000) that, in cases of inaction, Section 228 of the Tax Code grants the
taxpayer an option either to: (i) appeal to the CTA within 30 days from the lapse of
the 180 day period provided for under the said section; or (ii) wait until the CIR
decides on the protest before elevating the case to the CTA without rendering the
assessment final and executory.
The appeal from the CIRs decision or inaction is made by filing a petition for
review under a procedure analogous to that provided for under Rule 42 within 30
days from receipt of the decision or ruling or, in case of inaction, from the
expiration of the period prescribed by law to act thereon. The appeal shall be heard
by a division of the CTA.19
Local Tax Cases The CTA now has exclusive appellate jurisdiction over
decisions, orders or resolutions of RTCs in local tax cases, whether decided or
resolved by them in the exercise of their original or appellate jurisdiction. 20 If the
decision, order or resolution was decided or resolved by the RTC in the exercise of
its original jurisdiction, the appeal shall be taken by filing a petition for review
under a procedure analogous to the provisions of Rule 42 within 30 days from
receipt of the decision or ruling. The appeal shall be heard by a CTA division.21
On the other hand, if the decision, order or resolution was decided or resolved by
the RTC in the exercise of its appellate jurisdiction, the appeal shall be taken by
filing a petition for review under a procedure analogous to the provisions of Rule
43 within 30 days from receipt of the decision or ruling. The appeal shall be heard
en banc.22
It must be noted that the modes and periods of appeal to the CTA for local tax
cases are different from those applicable to ordinary civil actions. An appeal to the
Court of Appeals from a decision of the RTC in the exercise of its original
jurisdiction is taken by filing a notice of appeal within 15 days from notice of the
judgment or final order appealed from,23 while an appeal from a decision of the
RTC in the exercise of its appellate jurisdiction is taken by filing a petition for
review within 15 days from notice of the decision sought to be reviewed or of the
denial of petitioners motion for new trial or reconsideration filed in due time after
judgment.24
Customs Cases The CTA continues to exercise its appellate jurisdiction to
review by appeal decisions of the Commissioner of Customs in cases involving
liability for customs duties, fees or other money charges, seizure, detention or
release of property affected, fines, forfeitures or other penalties in relation thereto,
or other matters arising under customs laws or other laws administered by the
BOC.25
However, decisions of the Secretary of Finance on customs cases elevated to him
automatically for review from decisions of the Commissioner of Customs adverse
to the government under Section 2315 of the Tariff and Customs Code may now
also be appealed to the CTA.26

The appeal, either from a decision of the Commissioner of Customs or the


Secretary of Finance, should be made by filing a petition for review under a
procedure analogous to that provided for under Rule 42 within 30 days from
receipt of the decision or ruling. The appeal will be heard by a division of the
CTA.27
Real Property Assessments The CTA now has exclusive appellate jurisdiction
over decisions of the CBAAs in the exercise of its appellate jurisdiction over cases
involving assessment and taxation of real property decided originally by provincial
or city BAAs.28
Appeals from decisions of the CBAA may be taken by filing a petition for review
under a procedure analogous to the provisions of Rule 43 within 30 days from
receipt of the decision. The case shall be heard en banc.29
Decisions of the CBAA were previously appealed to the Court of Appeals by way
of a petition for review under Rule 43 within 15 days from notice of the award,
judgment, final order or resolution, or of the denial of petitioners motion for
reconsideration.30
Dumping and Countervailing Cases The CTA continues to exercise its
exclusive appellate jurisdiction over decisions of the Secretary of Trade and
Industry (in the case of non-agricultural products, commodities, or articles) and the
Secretary of Agriculture (in the case of agricultural products, commodities, or
articles) involving dumping and countervailing duties under section 301 and 302 of
the Tariff and Customs Code and safeguard measures under R.A. No. 8800.31
However, the appeal shall now be taken by filing a petition for review under a
procedure analogous to Rule 42 within 30 days from receipt of the decision,
instead of a petition for review under Rule 43. The appeal shall be heard by a
division of the CTA.32
Under R.A. No. 8800, the filing of the petition for review shall not in any way
stop, suspend or otherwise toll the imposition or collection of the appropriate tariff
duties or the adoption of other appropriate safeguards measures, as the case may
be.33
Criminal Cases - Original Jurisdiction The CTA now has exclusive original
jurisdiction over all criminal offenses arising from violations of the Tax Code,
Tariff and Customs Code and other laws administered by the BIR and BOC where
(i) the principal amount of taxes and fees, exclusive of charges and penalties,
claimed is at least P1,000,000.00; or (ii) there is no specified amount claimed.34
The Government may directly file the criminal case with the CTA. 35 However, the
criminal action and the corresponding civil action for the recovery of civil liability
for taxes and penalties shall at all times be simultaneously instituted with, and
jointly determined in the same proceeding by, the CTA. The filing of the criminal
action is deemed to necessarily carry with it the filing of the civil action, and no
right to reserve the filing of such civil action separately from the criminal action

shall be recognized similar to criminal actions for violation of the Bouncing


Checks Law,36 and offenses committed by public officers in relation to the duties. 37
This is a departure from the general rule in criminal procedure granting the
offended party a right to institute separately the civil action for the recovery of civil
liability of the offense charged.38
Granting the CTA original jurisdiction over criminal offenses without regard to the
place of commission is another express departure from the general rule on criminal
procedure relating to venue over criminal cases cognizable by regular courts
similar to criminal offenses cognizable by the Sandiganbayan. Criminal actions are
generally instituted and tried in the court of the municipality or territory where the
offense was committed or where any of its essential ingredients occurred primarily
to prevent the accused from being compelled to stand trial in a court outside the
province where the offense was committed and avoid expenses and inconvenience
in presenting his defense.39
On all other matters relating to prosecution of criminal offenses, the general rule
applicable in regular courts shall likewise apply in the CTA.40
Criminal Cases - RTC/MTC Original Jurisdiction Regular courts will have
jurisdiction over criminal offenses arising from violations of the Tax Code, Tariff
and Customs Code and other laws administered by the BIR and BOC where (i) the
principal amount or taxes and fees, exclusive of charges and penalties, claimed is
less thanP1,000,000.00; or (ii) there is no specified amount claimed.41
Under the present set up of regular courts, jurisdiction over criminal offenses is
generally determined on the basis of the imposable penalty expressed in numbers
of years. Metropolitan Trial Courts, Municipal Trial Court and Municipal Circuit
Trial Courts (MTC) have jurisdiction over criminal cases involving offenses
punishable with imprisonment not exceeding six years irrespective of the amount
of fine, and regardless of other imposable accessory or other penalties, including
the civil liability arising from such offenses or predicated thereon, irrespective of
kind, nature, value or amount thereof.42
On the other hand, criminal cases involving offenses punishable with
imprisonment exceeding six years fall within the jurisdiction of a RTC. 43 For
offenses where the only penalty provided by law is a fine, jurisdiction is
determined on the basis of the amount of imposable fine. If the amount of fine
exceeds P4,000.00, the RTC shall have jurisdiction over the case; if it does not
exceed such amount, the MTC shall have jurisdiction.44
Criminal Cases - Appellate Jurisdiction The CTA now has exclusive appellate
jurisdiction over judgments, resolutions, or orders of the RTC in criminal offenses
involving tax cases, whether decided or resolved by them in the exercise of their
original or appellate jurisdiction.45
The appeal may be taken by filing a petition for review under a procedure
analogous to Rule 42 if the decision, order or resolution was decided or resolved
by the RTC in the exercise of its original jurisdiction, while the appeal shall be

taken by filing a petition for review under a procedure analogous to Rule 43 if the
decision, order or resolution was decided or resolved by the RTC in the exercise of
its appellate jurisdiction. The appeal should, nonetheless, be filed within 30 days
from receipt of the decision in both cases.46
It must be noted that the modes and periods of appeal to the CTA for criminal cases
are different from those applicable to ordinary criminal cases. An appeal to the
Court of Appeals from a decision of the RTC in the exercise of its original
jurisdiction are taken by filing a notice of appeal within 15 days from promulgation
of the judgment or notice of the final order appealed from, 47 while an appeal from a
decision of the RTC in the exercise of its appellate jurisdiction are taken by filing a
petition for review under Rule 42 within 15 days from notice of the decision
sought to be reviewed or of the denial of petitioners motion for new trial or
reconsideration filed in due time after judgment.48
On all other matters relating to appeal of criminal offenses, the general rule
applicable in regular courts will likewise apply in the CTA.49
Tax Collection Cases - Original Cases The CTA now has exclusive original
jurisdiction over tax collection cases involving final and executory assessments for
taxes, fees, charges and penalties, except tax collection cases where the principal
amount of taxes and fees, exclusive of charges and penalties claimed is at least One
Million Pesos (P1,000,000.00).50 The Government is allowed to directly file the tax
collection case with the CTA.51
Tax Collection Cases RTC/MTC Original Jurisdiction Regular courts shall
have exclusive original jurisdiction over tax collection cases involving final and
executory assessments for taxes, fees, charges and penalties where the principal
amount of taxes and fees, exclusive of charges and penalties claimed is less than
One Million Pesos (P1,000,000.00).52
Under the present set up of regular courts, jurisdiction over collection cases is
generally determined on the basis of the amount sought to be collected as well as
the place where the courts sit. MTCs have jurisdiction over collection cases where
the amount sought to be collected does not exceed P400,000.00 if within Metro
Manila, and P300,000.00 if outside Metro Manila. 53 On the other hand, RTCs have
jurisdiction over collection cases where the amount sought to be collected exceeds
P400,000.00 if within Metro Manila, and P300,000.00 if outside Metro Manila.54
Tax Collection Cases -Appealed Cases The CTA now has exclusive appellate
jurisdiction over judgments, resolutions, or orders of the RTC in criminal offenses
involving tax cases, whether decided or resolved by them in the exercise of their
original or appellate jurisdiction.55 The appeal shall be taken by filing a petition for
review under a procedure analogous to Rule 42 if the decision, order or resolution
was decided or resolved by the RTC in the exercise of its original jurisdiction,
while the appeal shall be taken by filing a petition for review under a procedure
analogous to Rule 43 if the decision, order or resolution was decided or resolved
by the RTC in the exercise of its appellate jurisdiction. The appeal should,
nonetheless, be filed within 30 days from receipt of the decision in both cases.56

It must be noted that the modes and periods of appeal to the CTA for tax collection
cases are different from those applicable to ordinary collection cases before regular
courts. An appeal to the Court of Appeals from a decision of the RTC in the
exercise of its original jurisdiction is taken by filing a notice of appeal within 15
days from notice of the judgment or final order subject to the appeal, 57 while an
appeal from a decision of the RTC in the exercise of its appellate jurisdiction is
taken by filing a petition for review within 15 days from notice of the decision
sought to be reviewed or of the denial of petitioners motion for new trial or
reconsideration filed in due time after judgment.58
Injunctive Relief
As a rule, no appeal taken to the CTA from the decision of the CIR, the
Commissioner of Customs, the RTC, provincial city or municipal treasurer, the
Secretary of Finance, the Secretary of Trade and Industry and Secretary of
Agriculture, as the case may be, shall suspend the payment, levy, distraint, and /or
sale of any property of the taxpayer for the satisfaction of his tax liability as
provided by existing law. However, when in the opinion of the CTA the collection
by the aforementioned government agencies may jeopardize the interest of the
Government and/or the taxpayer, the CTA may, at any stage of the proceeding,
suspend the collection and require the taxpayer either to deposit the amount
claimed or to file a surety bond for not more than double the amount with the
CTA.59
Decisions and Maximum Period for Termination of Cases
Cases brought before the CTA shall be decided in accordance with 1987
Constitution, Article VIII (Judicial Department), section 15[1] which provides that
all cases or matters filed with collegiate courts after the 1987 Constitution must be
decided or resolved within 12 months from the date the case or matter is submitted
for decision or resolution.60
Decisions of the CTA are mandated to be in writing, stating clearly and distinctly
the facts and the law on which they are based, and signed by the concurring
Justices. The CTA shall provide for the publication of its decisions in the Official
Gazette in such form and manner as may best be adopted for public information
and use.61
Distraint of Personal Property and/or Levy on Real Property
Upon the issuance of any ruling, order or decision by the CTA favorable to the
national government, the CTA shall issue an order authorizing the BIR, through the
CIR, to seize and distraint any goods, chattels, or effects, and the personal property,
including stocks and other securities, debts, credits, bank accounts, and interest in
and rights to personal property and/or levy the real property of such person in
sufficient quantity to satisfy the tax or charge together with any increment thereto
incident to delinquency.
This remedy shall not be exclusive and shall not preclude the CTA from availing of
other means under the Rules.62

Motion for Reconsideration and appeal to the CTA en banc


A party adversely affected by a ruling, order or decisions of a Division of the CTA
may file a motion for reconsideration or new trial before the same Division of the
CTA within 15 days from notice thereof.63
A party adversely affected by a resolution of a CTA Division on a motion for
reconsideration or new trial may file a petition for review with the CTA en banc.
The period for filing an appeal from a resolution of CTA Division to the CTA en
banc is not however expressly provided under the law.64
Prior to the passage of R.A. No. 9282, decisions of the CTA could be elevated to
the Court of Appeals via petitions for review under Rule 43 within 15 days from
receipt of the decision of the CTA or of the denial of petitioners motion for new
trial or reconsideration.65
Appeal to the Supreme Court
A party adversely affected by a decision of the CTA en banc may file with the
Supreme Court a petition for review on certiorari pursuant to Rule 45 within 15
days from notice of the judgment or final order or resolution appealed from, or of
the denial of petitioners motion for new trial or reconsideration filed in due time
after notice of the judgment. 66 This is similar to the appellate procedure established
upon the creation of the CTA (but before Administrative appellate jurisdiction over
decisions of the CTA was transferred to the Court of Appeals) where the party
adversely affected may appeal any ruling, order or decision of the CTA directly to
the Supreme Court by filing a notice of appeal with the CTA and a petition for
review with the Supreme Court within 30 days from receipt of the decision.67
______ ! ______
The author is an associate of SyCip Salazar Hernandez & Gatmaitan.
1 See Sen. Franklin Drilons sponsorship speech on December 1, 2003 at the Second Reading of Senate Bill No. 2712
Expanding the
Jurisdiction of the CTA.
2 See Deliberations of the Senate Committee on Ways and Means, October 15, 2003 re Elevation of CTA to a Collegiate Court at
page 2.
3 See University of Santo Tomas v. Board of Tax Appeals 93 Phil 376 [1953].
4 See Republic of the Philippines v. Abella, 102 SCRA 743 [1981].
5 See R.A. No. 1125, section 7 before its amendment.
6 See P.D. No. 464, section 36 and R.A. No. 7160, section 230.
7 See R.A. No. 8800, section 29.
8 See R.A. No. 1125, section 1 before its amendment.
9 See R.A. No. 1125, section 1 as amended.
10 See R.A. No. 1125, section 1 as amended.
11 See 1987 Constitution, Article VII, section 2 on reorganization of the judiciary.
12 See R.A. No. 1125, section 1 as amended.
13 See R.A. No. 1125, section 1 as amended.
14 See R.A. No. 1125, section 5 as amended.
15 See R.A. No. 1125, section 1 as amended.
16 See R.A. No. 1125, section 5 as amended.
17 See R.A. No. 1125, section 7[1] as amended.
18 See R.A. No. 1125, section 7[2] as amended.
19 See R.A. No. 1125, section 11 as amended.
20 See R.A. No. 1125, section 7[3] as amended.
21 See R.A. No. 1125, section 11 as amended.
22 See R.A. No. 1125, section 11 as amended.
23 See Rule 41, sections 2 and 3.
24 See Rule 42, section 1.
25 See R.A. No. 1125, section 7[4] as amended.
26 See R.A. No. 1125, section 7[4] as amended.
27 See R.A. No. 1125, section 11 as amended.
28 See R.A. No. 1125, section 7[4] as amended.
29 See R.A. No. 1125, section 11 as amended.
30 See section 1.

See R.A. No. 1125, section 7[7] as amended; see also R.A. No. 8800, section 29.
See R.A. No. 1125, section 11 as amended and R.A. No. 8800, section 29.
33 See section 29.
34 See R. A. No. 1125, section 7[b][1] as amended.
35 See R.A. No. 1125, section 11 as amended.
36 See Rule 111, section 1[b].
37 See P.D. No. 1606 as amended by P.D. No. 1861.
38 See Rule 111, section 1[a].
39 See Rule 110, section 15[a].
40 See R.A. No. 1125, section 11 as amended.
41 See R.A. No. 9282, section 7[b][1] as amended.
42 See BP 129, section 32[2] as amended by R.A. No. 7691.
43 See BP 129, section 20 as amended by R.A. No. 7691.
44 See B.P. Blg 129, section 32 as amended by R.A. No. 7691.
45 See R.A. No. 1125, sections 7[b][2][a] and 7[b][2][b] as amended.
46See R.A. No. 1125, section 11 as amended.
47 See Rule 122, sections 3[a] and 6).
48 See Rule 122, section 3[b].
49 See R.A. No. 1125, section 11 as amended.
50 See R.A. No. 1125, section 7[c] as amended.
51 See R.A. No. 1125, section 11 as amended.
52 See R.A. No. 1125, section 7[c] as amended.
53 See B.P. Blg. 129, section 33[1] as amended by R.A. No. 7691.
54 See B.P. Blg. 129, sections 31[8] as amended by R.A. No. 7691.
55 See R.A. No. 1125, sections 7[c][2][a] and 7[c][2][b] as amended.
56 See R.A. No. 1125, section 11 as amended.
57 See Rule 41, sections 2 and 3.
58 See Rule 42, section 1.
59 See R.A. No. 1125, section 11 as amended.
60 See R.A. No. 1125, section 13 as amended.
61 See R.A. No. 1125, section 13 as amended.
62 See R.A. No. 9282, section 13.
63 See R.A. No. 1125, section 11 as amended.
64 See R.A. No. 1125, section 18 as amended.
65 See Administrative Circular No. 1-95 and Rule 43, section 1.
66 See R.A. No. 1125, section 19 as amended in relation to Rule 45, section 2.
67 See R.A. No. 1125, section 18 before its amendment.
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