Puyat Steel Corp. v. Central Board of Assessment Appeals, G.R. No. 174351 (Notice), (February 18, 2015).

A letter addressed to the Provincial Assessor, thru the Municipal Mayor is not the appeal contemplated that would stop the running of the 60-day reglementary period. Under Section 226, appeal of the assessment of the property is done by filing before the LBAA “a petition under oath in the form prescribed for the purpose, together with the copies of the tax declarations and such affidavits or documents submitted in support of the appeal.” The party who appeals must comply with the procedures and rules governing appeals. The perfection of an appeal in the manner and within the period permitted by law is not only mandatory, but jurisdictional, and the failure to perfect that appeal renders the judgment of the court final and executory. See Puyat Steel Corp. v. Central Board of Assessment Appeals, G.R. No. 174351 (Notice), (February 18, 2015).

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