Practice question
A civil tax litigant files a Rule 45 petition asking the Supreme Court only to reweigh witness credibility and choose between competing invoice evidence. It identifies no legal question or recognized exception permitting factual review. Which problem is central?
- Every tax petition requires no grounds
- The Supreme Court must conduct a new trial in every case
- The petition seeks ordinary factual re-evaluation rather than the questions of law contemplated by Rule 45
- Every invoice is automatically inadmissible
- All tax evidence is conclusive forever
Legal references
- Rules of Court, Rule 45, Section 1: https://lawphil.net/courts/supreme/rc/rc_1-71_civil.html
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