SPECIAL TENTH DIVISION
[CA-G.R. SP NO. 128320. September 15, 2014.]
LEGAZPI CITY WATER DISTRICT, duly rep. by its Officer-in-Charge, MA. LOURDES B. BIEN, petitioner-appellant,vs. THE BUREAU OF INTERNAL REVENUE (BIR), AS REP. BY ITS OIC REGIONAL DIRECTOR MR. EDGARDO P. CLAVERIA, BIR REVENUE REGION NO. 10, LEGAZPI CITY, ET AL., respondents-appellees.
DECISION
ANTONIO-VALENZUELA, J p:
This is the appeal filed by Legazpi City Water District ("petitioner-appellant LCWD"), assailing the Decision dated 6 September 2012 1 ("assailed Decision") issued by the Regional Trial Court, Branch 7, Legazpi City ("RTC"), in Civil Case No. 10748 (a special civil action for prohibition filed under Rule 65 of the Rules of Court), entitled "Legazpi City Water District, duly represented by its General Manager, Dr. Raul L. Chua v. The Bureau of Internal Revenue (BIR), as represented by its OIC Regional Director Mr. Edgardo P. Claveria, BIR Revenue Region No. 10, Legazpi City, et al."
The facts are as follows: on 9 July 2007, the Regional Director of the Bureau of Internal Revenue ("respondent-appellee BIR"), Revenue Region No. 10, Legazpi City issued the Preliminary Assessment...
