There is a question of fact when the doubt or difference arises as to the truth or falsehood of facts or when the query invites calibration of the whole evidence considering mainly the credibility of the witnesses, the existence and relevancy of specific surrounding circumstances as well as their relation to each other and to the whole, and the probability of the situation. – Republic of the Philippines v. Sandiganbayan, 426 Phil. 104, 110 (2002).
Medicard vs. CIR Digest
Facts CIR found discrepancies in the ITR of Medicard. It then issued a Letter of Notice (LN) to Medicard, then PAN, then FAN. No issuance of LOA to the revenue officer. Arguments CIR: