2016 Taxation Law, Q2

State at least five (5) cases under the exclusive appellate jurisdiction of the Court of Tax Appeals (CTA). (5%)

Quick check

Which court exercises exclusive appellate jurisdiction over decisions of the Commissioner of Internal Revenue in disputed assessments?

Which entity's decisions regarding real property tax assessments are appealable directly to the Court of Tax Appeals?

To which court may a judgment rendered by a Regional Trial Court in a local business tax case be appealed?

Does the Court of Tax Appeals exercise appellate jurisdiction over decisions of the Commissioner of Customs?

Which court has exclusive appellate jurisdiction over judgments rendered by Regional Trial Courts in criminal tax cases?

Learn more about these topics

1. CTA Appellate Scope
Under Section 7 of Republic Act No. 1125, as amended by Republic Act No. 9282, the Court of Tax Appeals possesses exclusive appellate jurisdiction over decisions of the Commissioner of Internal Revenue involving disputed assessments, tax refunds, or penalties. This specialized appellate jurisdiction ensures that technical tax disputes are reviewed by a collegiate court with specialized tax expertise. In cases where the Commissioner fails to act on an administrative protest or claim for tax refund within the prescribed statutory period, the inaction is deemed an implied denial appealable directly to the Court of Tax Appeals.

2. Customs Local Taxes
The Court of Tax Appeals also exercises exclusive appellate jurisdiction over decisions rendered by the Commissioner of Customs in cases involving customs duties, seizure, forfeiture, or other matters arising under the Customs Modernization and Tariff Act. Furthermore, the appellate jurisdiction extends to local tax cases decided by Regional Trial Courts in the exercise of their original or appellate jurisdiction, as well as decisions rendered by the Central Board of Assessment Appeals regarding real property tax assessments. This ensures unified judicial supervision over both national and local revenue measures.

3. Criminal Tax Jurisdiction
In addition to civil tax cases, the Court of Tax Appeals exercises exclusive appellate jurisdiction over criminal offenses involving violations of the National Internal Revenue Code, the Customs Modernization and Tariff Act, and other tax laws. When a Regional Trial Court renders a judgment or order in a criminal tax case, whether in the exercise of its original or appellate jurisdiction, the appeal must be elevated directly to the Court of Tax Appeals En Banc or Division as prescribed by law. This specialized criminal review prevents conflicting rulings in tax enforcement prosecutions.

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The questions reproduced here are the official texts of the Philippine Bar Examinations, published by the Supreme Court. They are reproduced for study purposes.The suggested answers are the author’s own.

They are not official answers, have no connection with the Supreme Court, the Office of the Bar Confidant, or any bar review institution, and are not endorsed by any of them. Official answer keys, where released, should be preferred over anything here.Nothing on this page is legal advice, and reading it creates no lawyer-client relationship. Do not rely on any suggested answer in an actual legal matter. Consult counsel on your own facts.Suggested answers reflect the law and jurisprudence the author considers applicable as of the date shown.

Where a question comes from an earlier examination, the suggested answer applies the law as it now stands, which may differ from the law in force when the question was given, and may therefore differ from what would have been the correct answer at that time. Where the difference is material, the answer notes it.The practice scoring feature measures wording overlap with the suggested answer. It is not a grade, carries no official weight, and says nothing about whether your reasoning is sound.Errors are possible. If you find one, please tell me and I will correct it.Last reviewed: October 2026