G.R. No. 222428 - COCA-COLA BOTTLERS PHILIPPINES, INC., V. COMMISSIONER OF INTERNAL REVENUE.

Ruling

accordingly developed an expertise on the subject of taxation. Thus, its decisions are presumed valid in every aspect and will not be overturned on appeal, unless the Court finds that the questioned decision is not supported by substantial evidence or there has been an abuse or improvident exercise of authority on the part of the tax court. [38] Upon careful review of the instant case, the Court finds no cogent reason to reverse or modify the findings of the CTA Division, as affirmed by the CTA En Banc . Petitioner's assertion, therefore, in its petition, that its claim deserves a greater weight of evidence for the same necessitates only a preponderance of evidence must certainly fail. It cannot be allowed, at this stage of the proceedings, to seek a review by the Court of the factual findings of the CTA Division, as affirmed by the CTA En Banc , as well as a re-examination of the evidence it presented, taking into account the quantum of proof required in the instant case. Settled is the rule that this Court is not a trier of facts and does not normally embark in the evaluation of evidence adduced during trial. [39] It is not this Court's function to analyze or weigh all over again the evidence already considered in the proceedings below. [40] In a petition for review on certiorari under Rule 45 of the Rules of Court, moreover, only questions of law may be raised, the Court's jurisdiction being limited to reviewing only errors of law that may have been committed by the lower court. [41] Thus, the Court shall not undertake the re-examination of the evidence presented by petitioner especially since the findings of facts of the CTA Division are affirmed by the CTA En Banc . On a final note, the Court reiterates its consistent ruling that actions for tax refund or credit, as in the instant case, are in the nature of a claim for exemption and the law is not only construed in strictissimi juris against the taxpayer, but also the pieces of evidence presented entitling a taxpayer to an exemption is strictissimi scrutinized and must be duly proven. [42] The burden is on the taxpayer to show that he has strictly complied with the conditions for the grant of the tax refund or credit. [43] Since taxes are the lifeblood of the government, tax laws must be faithfully and strictly implemented as they are not intended to be liberally construed. [44] Thus, in view of petitioner's failure to prove, to the satisfaction of the Court, its entitlement to the grant of tax refund or issuance of tax credit of input VAT in the amount of P123,459,647.70 it inadvertently failed to include in its VAT Return, the Court deems it necessary to deny the same. WHEREFORE , premises considered, the instant petition is DENIED . The assailed Resolution dated January 14, 2016 and Decision dated August 12, 2015 of the Court of Tax Appeals En Banc in CTA EB No. 1111, which affirmed the Decision dated September 16, 2013 and Resolution dated December 4, 2013 of the CTA Division denying pet