FACTS:

Petron Corporation (Petron) filed a petition for review before the Court of Tax Appeals (CTA), questioning the classification of alkylate and the imposition of excise tax by the Commissioner of Internal Revenue (CIR). The CTA initially dismissed Petron's petition but later reversed its decision and gave due course to the petition. The CIR filed a motion for reconsideration, but it was denied by the CTA. The CIR then elevated the case to the Court through a petition for certiorari, alleging that the CTA lacked jurisdiction and there was no final decision by the Commissioner of Customs (COC) that was appealable to the CTA. In a decision, the Court upheld the CIR's position and ordered the dismissal of Petron's petition. Petron filed a motion for reconsideration.

ISSUES:

1. Whether or not the Court's July 15, 2015 Decision, which ordered the dismissal of Petron's petition for review before the CTA on the grounds of lack of jurisdiction and prematurity, should be reconsidered.

RULING:

1. The Court denied the motion for reconsideration filed by Petron and upheld its previous decision. The Court reiterated that the CTA does not have jurisdiction to decide on the constitutionality or validity of a law, rule, or regulation, and that Petron should have first protested the customs collector's assessment and appealed to the Commissioner of Customs before resorting to judicial action. Thus, the dismissal of Petron's petition for review remains in effect.

PRINCIPLES:

• The Court of Tax Appeals (CTA) does not have jurisdiction to decide on the constitutionality or validity of a law, rule, or regulation.

• A protest and appeal to the Commissioner of Customs must be made before resorting to judicial action.