Rule 64 Rule 65

Rule 64:
Directed only to the
judgments, final
orders or resolutions
of COMELEC and COA

Rule 65:
Directed to any
tribunal, board, or
officer exercising
judicial or quasijudicial
functions

Rule 64:
Filed within 30 days
from notice of the
judgment

Rule 65:
Filed within 60 days
from notice of the
judgment

Rule 64:
The filing of a MR or a
Motion for New Trial if
allowed, interrupts the
period for the filing of
the petition for
certiorari. If the
motion is denied, the
aggrieved party may
file the petition within
the remaining period,
but which shall not be
less than 5 days
reckoned from the
notice of denial.

Rule 65:
The period within
which to file the
petition if the MR or
new trial is denied, is
60 days from notice of
the denial of the
motion.

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No appeal taken to the CTA from the decision of the Commissioner of Internal Revenue or the
Commissioner of Customs or the Regional Trial Court, provincial, city or municipal treasurer or the
Secretary of Finance, the Secretary of Trade and Industry and Secretary of Agriculture, as the case
may be shall suspend the payment, levy, distraint, and/or sale of any property of the taxpayer for the
satisfaction of his tax liability as provided by existing law: Provided, however, That when in the
opinion of the Court the collection by the aforementioned government agencies may jeopardize the
interest of the Government and/or the taxpayer the Court any stage of the proceeding may suspend
the said collection and require the taxpayer either to deposit the amount claimed or to file a surety
bond for not more than double the amount with the Court.

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