G.R. No. 5483 - Marasigan vs. Moore

The petitioner is the People of the Philippines, seeking the annulment of orders of the respondent Judge Mariano Castaneda, Jr., who quashed several criminal informations against accused respondents Vicente Lee Teng, Priscilla Castillo Vda. de Cura, and Francisco Valencia.
The basis for quashing was that accused Francisco Valencia was entitled to tax amnesty under Presidential Decree No. 370 (P.D. No. 370) and that the dismissal of Valencia's criminal cases inured to the benefit of his co-accused Vicente Lee Teng and Priscilla Castillo de Cura.
The People’s Motions for Reconsideration of the orders quashing the cases were denied by the respondent Judge.

In 1971, two informants submitted sworn information to the Bureau of Internal Revenue (BIR) under Republic Act No. 2338 for alleged violations of the Internal Revenue Code by the respondents.
The BIR conducted investigations, obtained search warrants, examined seized materials, and filed criminal informations against the respondents.

Criminal Case No. 439 — charging Francisco Valencia, Apolonio Erespe y Comia, and Priscilla Castillo de Cura for possession of false and counterfeit internal revenue labels, violating Section 170(2) of the National Internal Revenue Code.
Criminal Case No. 440 — charging the same persons for possession of locally manufactured articles subject to specific tax with unpaid tax, violating Section 174(3) of the National Internal Revenue Code.

On 14 March 1974, six more informations (Criminal Cases Nos. 538-543) were filed against Vicente Lee Teng and Francisco Valencia for failure to pay annual privilege taxes from 1966 to 1972, violating Section 178 in relation to Sections 182(A)(1)(3c) and 208 of the Internal Revenue Code.

On 22 April 1974, after arraignment, accused Valencia filed a Motion to Quash Criminal Cases Nos. 538-543 on grounds of lack of preliminary investigation and entitlement to tax amnesty under P.D. No. 370.
The prosecution opposed the Motion, asserting the preliminary investigation was held and that cases were already the subject of valid information under R.A. No. 2338 as of 31 December 1973, thus precluding amnesty.
On 15 July 1974, the respondent Judge granted Valencia’s Motion to Quash, dismissing not only Criminal Cases Nos. 538-543 but also Criminal Cases Nos. 439 and 440 insofar as Valencia was concerned.
The People’s Motion for Reconsideration was denied on 18 November 1974.
On 14 December 1975, co-accused Vicente Lee Teng and Priscilla Castillo de Cura filed Motions to Quash the same cases based on the benefit of the dismissal granted to Valencia.
The Judge granted the Motions to Quash by Lee Teng and Castillo de Cura on 31 March 1976 and denied the People’s Motion for Reconsideration on 17 February 1977.

Laches - private respondents argued the People’s petition was barred by laches due to delay.
Double Jeopardy - private respondents argued dismissal prevented reprosecution.

P.D. No. 370 grants tax amnesty to those who failed to avail of earlier amnesties or failed to declare all taxable income prior to 1973, allowing condonation of all internal revenue taxes, penalties, and liabilities upon payment of 15% tax on previously untaxed income or wealth.
The amnesty excludes:

Cases that were the subject of a valid information under R.A. No. 2338 as of December 31, 1973, among others.

In this case, the respondent accused were charged based on sworn information filed with the BIR under R.A. No. 2338 before December 31, 1973, thus excluding them from the benefits of P.D. No. 370.

Whether accused Francisco Valencia was entitled to tax amnesty under Presidential Decree No. 370 despite criminal informations filed against him based on sworn complaints under R.A. No. 2338 prior to December 31, 1973.
Whether the dismissal of the criminal cases against accused Valencia inured to the benefit of his co-accused Vicente Lee Teng and Priscilla Castillo de Cura.
Whether the People’s Petition for Certiorari and Mandamus is barred by laches due to delay in filing.
Whether the defense of double jeopardy is available to the accused due to the dismissal of the cases.