Facts:

In the case of People of the Philippines v. Court of Appeals, et al., G.R. No. 125164, decided on September 25, 1998, the petitioner-appellant is the People of the Philippines while the respondents-appellees include Lorenzo Veneracion (presiding judge), Ricardo B. Bangayan, Benjamin Bangayan, Jr., Roberto Bangayan, Rodrigo Bangayan, Lanie L. Zipagan, Almario Amador, Manny Sia, Jose "Pepe" Aguilar, Angelito Chua, Eduardo R. Ignacio, Bernadette C. Cristobal, Oscar L. Macalino, Hilario L. Culla, Basilio B. Zapata, and Ricardo J. Ebuna. The case originated from an information filed on March 30, 1993, by State Prosecutor Brenda P. Lumabao with the Regional Trial Court of Manila. The accused were charged with violations of Section 3602 in relation to Section 3601 of the Tariff and Customs Code of the Philippines regarding the unlawful importation of 64,480 bags of PVC resins. Allegedly, they conspired to misrepresent payments of customs duties amounting to P13,265,225.00 whi

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Facts:

Background of the Case

• On March 30, 1993, the State Prosecutor, Brenda P. Lumabao, of the Department of Justice filed an information in the Regional Trial Court (RTC) of Manila against a group of private respondents.
• The information charged the respondents with violating Section 3602 in relation to Section 3601 of the Tariff and Customs Code of the Philippines (TCCP).
• Allegedly, from July 16, 1992 to August 12, 1992, the accused, in concert and through mutual assistance, caused the entry of approximately 64,480 bags (more or less) of imported PVC resins from Busan, Korea, through three shipments.
• The import shipments were consigned to companies purportedly named Peaks Marketing, LBZ Commercial, and Final Sales Enterprises.
• They allegedly secured the release of these shipments from the Manila International Container Port by using Bureau of Customs Official Receipts (BCORs) issued by RCBC, which were alleged to represent final payments of customs duties and other charges.

Payment and Defense Raised by the Accused

• The respondents contended that payment of the customs duties and other charges, amounting to P13,265,225.00, was fully remitted to the Bureau of Customs through RCBC.
• They presented three RCBC Official Receipts indicating payments of P4,431,099.00, P4,901,396.00, and P4,132,730.00, respectively, together with the required Central Bank Release Certificates.
• The respondents maintained that upon issuance of these receipts and clearances, any irregularity in the importation was thus “condoned” or deemed legally extinguished.
• They also argued that the withdrawal of 14 truckloads of PVC resins on September 20 and 21, 1992, from a warehouse in Caloocan City was covered by a valid Temporary Restraining Order issued by the RTC of Manila.

Trial Court Decision and Subsequent Motions

• In an order dated May 19, 1993, the RTC dismissed Criminal Case No. 93-118715, reasoning that the alleged non-payment of duties was not proven given the remittance acknowledged by the Bureau of Customs.
• The court noted that the evidence of proper accreditation of the importers and the issuance of valid Letters of Credit supported compliance with legal requirements.
• Following the dismissal, the petitioner (the State) filed an omnibus motion to quash the information based on procedural grounds, contending that:
• The facts charged did not constitute an offense;
• The criminal liability was already extinguished by the remittance; and
• The averments in the information, even if proven, would justify legal excuses.

Filing of the Motion for Reconsideration and Its Defects

• Petitioner filed a motion for reconsideration on June 8, 1993, and received the trial court’s order dismissing it on the grounds that no notice of hearing had been set.
• Petitioner’s subsequent motion on July 1, 1993, to set the hearing for the reconsideration was deemed belated, as the order had become final on June 19, 1993.
• An extension and later a petition for review on certiorari were also filed with the Supreme Court, which were later scrutinized for timeliness and procedural compliance.

Court of Appeals and Supreme Court Proceedings

• The Court of Appeals, in its decision of May 23, 1997, denied the petitioner’s petition on multiple grounds, including the late filing of motions and the procedural defects inherent in the motion for reconsideration.
• The Supreme Court later reviewed the case and eventually affirmed the ruling of the Court of Appeals, emphasizing that the petitioner’s failure to comply with the rules on notice of hearing resulted in a lost appeal.

Issue:

Timeliness and Procedural Sufficiency

• Whether the motion for reconsideration filed by the petitioner was valid despite its failure to provide a proper notice of hearing.
• Whether the subsequent motion to set the hearing on July 1, 1993, could effectively cure the initial procedural defect.

Validity of Payment as a Defense

• Whether the remittance of customs duties, evidenced by the RCBC Official Receipts and Central Bank Release Certificates, constitutes a valid defense that extinguishes criminal liability under Section 3602 of the TCCP.
• Whether the absence of evidence of “apprehension” (as legally defined) undermines the petitioner’s contention that the offense was committed prior to the payment.

Impact of Extension and Special Civil Action for Certiorari

• Whether the petition for review on certiorari, even if treated as a special civil action, can be used as a substitute for the lost appeal remedy.
• Whether the filing of an extension of time mitigates the impact of having initially filed the motion for reconsideration outside the prescribed reglementary period.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)