Case Digest (G.R. No. L-17177-80)
Facts:
- Ildefonso Tierra was found guilty by the Manila Court of First Instance for income tax law violations.
- The case was elevated to the Supreme Court due to questions of law.
- Four informations were filed against Tierra on December 12, 1955:
- The first information accused him of filing a false and fraudulent income tax return for 1946.
- The second information accused him of underreporting his income for 1947.
- The third information charged him, as president of "Ildefonso Tierra & Sons, Inc.," with filing a false return for the corporation for 1949.
- The fourth information charged him with failing to keep and preserve his and the corporation's books of account.
- The trial court found Tierra guilty on all counts, imposing fines, imprisonment, and indemnity payments.
- Tierra appealed, arguing the informations were void, the actions had prescribed, his criminal liability was extinguished by the extinguishment of his civil liability, and the law he was accused of violating had been repealed.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the informations were not void.
- The actions against Tierra had not prescribed.
- Tierra's criminal liability was not extinguished by the extinguishment of his civil liabi...(Unlock)
Ratio:
- The informations were not void because they sufficiently alleged the income, and it was unnecessary to allege age, residence, or citizenship, as Tierra had submitted his income return, implying he was bound to make it.
- Regarding prescription, the court noted that the falsity of the returns and the failure to preserve books were discovered on December 16, 1950, and the informations were filed on December 12, 1955, within the five-year period of limitation.
- The court clarified that the failure of the governme...continue reading
Case Digest (G.R. No. L-17177-80)
Facts:
The case of "People vs. Tierra" involves the defendant-appellant, Ildefonso Tierra, who was found guilty by the Manila Court of First Instance for violations of the income tax law. The case was elevated to the Supreme Court upon certification by the Court of Appeals, as it raised questions of law. Four separate informations were filed against Tierra on December 12, 1955. The first information accused him of filing a false and fraudulent income tax return for the year 1946, underreporting his net income and refusing to pay the deficiency tax. The second information similarly accused him of underreporting his income for 1947. The third information charged him, in his capacity as president of "Ildefonso Tierra & Sons, Inc.," with filing a false return for the corporation for 1949. The fourth information charged him with failing to keep and preserve his own and the corporation's books of account for the required period. The trial court found Tierra guilty on all counts, imposing fines, imprisonment, and indemnity payments to the government. Tierra appealed the judgment, arguing that the informations were void, the actions had prescribed, his criminal liability was extinguished by the extinguishment of his civil liability, an...