Manila: The Court of Tax Appeals (CTA) has dismissed a petition filed by the local government of Marinduque against MR Holdings Ltd., a Cayman Islands-registered firm, regarding property ownership and redemption rights. The local government unit (LGU) of Marinduque challenged the Regional Trial Court's (RTC) decision concerning MR's claims to ownership and redemption rights to properties previously owned by Marcopper Mining Corporation. These properties had been auctioned off by the local government due to non-payment of realty taxes.

According to Philippines News Agency, the CTA issued a 13-page decision in July, stating it lacks jurisdiction over the case as it does not involve a tax issue. The court explained that the RTC's decision ordered the petitioners to allow MR Holdings to exercise its right of redemption on select properties. The petitioners based their challenge on several points, including the constitutional prohibition on foreign ownership of local land, the respondent's alleged failure to prove its legal interest, the prescription of the respondent's right of redemption, and the bar against the exercise of such right.

The CTA highlighted that the arguments in question do not pertain to tax issues. It noted that the term "tax" appeared only 11 times throughout the arguments and was not actually associated with tax-related issues in the petitioner's discussions.

In a separate decision, the CTA dismissed a petition for review by a local firm challenging a PHP7 million tax assessment. The court found that the motion to contest the assessment was filed late. In a 23-page decision, the court dismissed the suit filed by South Cotabato Integrated Port Services Inc., based in General Santos City. Associate Justice Henry Angeles wrote the ruling, stating that the petitioner lost the right to dispute the tax assessments by failing to timely perfect its recourse from the FDDA (Final Decision on Disputed Assessment).

The court explained that the validity of a tax assessment that has become final cannot be challenged through a claim for a refund. The Bureau of Internal Revenue's Large Taxpayer Division determined that more than 30 days had elapsed from the firm's receipt of the FDDA to the filing of its motion for reconsideration. As a result, the tax assessments had become final, executory, and enforceable.