This ruling prompted petitioner to file an appeal with the Department of Finance (DOF). Petitioner directly appealed to this Court under Rule 45 of the 1997 Rules of Civil Procedure, assailing the aforesaid Decision and Resolution of the CTA Division.ISSUE: W/N petitioner had wrong mode of appeal by directly availing itself of the remedies before this Court without first elevating the case to the CTAen bancas provided under Rule 16 of the Revised Rules ofthe CTA.RULING: This Court has had a long-standing rule that a court's jurisdiction over the subject matter of an action is conferred only by the Constitution or by statute.In this regard, we find that petitioner's direct appeal to this Court is fatal to its claim.The CTA came into being with the passage of R.A. No. 1125on 16 June 1954.Section 18 of this law provides for the manner in which an appeal from the decision of the CTA to the Supreme Court is made, to wit:Section 18. Appeal to the Supreme Court.- No judicial proceeding against the Government involving matters arising under the National Internal Revenue Code, the Customs Law or the Assessment Law shall be maintained, except as herein provided, until and unless an appeal has been previously filed with the Court of Tax Appeals and disposed of in accordance with the provisions of this Act.Any party adversely affected by any ruling, order or decision of the Court of Tax Appeals may appeal therefrom to the Supreme Court by filing with the said Court a notice of appeal and with the Supreme Court a petition for review, within thirty days from the date he receives notice of said ruling, order or decision. If, within the aforesaid period, he fails to perfect his appeal, the said ruling, order or decision shall become final and conclusive against him.If no decision is rendered by the Court within thirty days from the date a case is submitted for decision, theparty adversely affected by said ruling, order or decision may file with said Court a notice of his intention to appeal to the Supreme Court, and if, within thirty days from the filing of said notice of intention to 11
appeal, no decision has as yet been rendered by the Court, the aggrieved party may file directly with the Supreme Court an appeal from said ruling, order or decision, notwithstanding the foregoing provisions of this section.If any ruling, order or decision of the Court of Tax Appeals be adverse to the Government, the Collector of Internal Revenue, the Commissioner of Customs, or the provincial or city Board of Assessment Appeals concerned may likewise file an appeal therefrom to the Supreme Court in the manner and within the same period as above prescribed for private parties.Any proceeding directly affecting any ruling, order or decision of the Court of Tax Appeals shall have preference over all other civil proceedings except habeas corpus, workmen's compensation and election cases.