Case Summary (G.R. No. 190487)
Background of Proceedings
From June 2005 to January 2007, MSPI engaged in the importation of 255,870,000 pieces of printed bet slips and 205,200 rolls of thermal papers from Australia. These items were meant for PCSO’s lottery operations in Luzon. However, MSPI did not comply with the payment of duties and taxes, prompting the Bureau of Customs to initiate legal action against the respondents. The complaint was filed under the Bureau's Run After The Smugglers (RATS) Program, alleging violations of applicable sections of the Tariff and Customs Code of the Philippines and relevant laws.
Initial Legal Findings
On March 25, 2008, the State Prosecutor found probable cause to charge MSPI and its key personnel with violations under the Tariff and Customs Code. A petition for review was subsequently filed, but before the resolution of that petition, an Information was filed in the Court of Tax Appeals (CTA) on April 11, 2009. The notice indicated unlawful importations involving a total value exceeding one million US dollars, as well as total unpaid duties estimated at approximately Php 15,917,611.83.
Procedural Developments
Respondents Cajigal and Lingan were served warrants of arrest and posted bail. However, on March 20, 2009, the Secretary of Justice reversed the initial finding of probable cause and directed the withdrawal of the Information. This led to further proceedings where the Bureau of Customs contested this decision, ultimately filing a petition for certiorari before the Court of Appeals after the CTA allowed the withdrawal of the charges and dismissed the Information.
Role of Public Prosecutors
The court emphasized the critical role of public prosecutors, stating that the prosecution of crimes is primarily an executive function, characterized by the government's responsibility to execute laws. Even though special prosecutors can assist, the core control of criminal prosecution resides with public prosecutors.
Entry of Judgment and Consequence of Actions
The CTA’s later resolution noted without action the petitioner’s motion for reconsideration as it had already issued an Entry of Judgment, effectively deeming the matter concluded. The court reiterated that the authority to manage the prosecution
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Case Overview
- The case involves the Bureau of Customs (petitioner) and several respondents, including Mark Sensing Philippines, Inc. (MSPI) officials, accused of unlawful importation of finished betting slips and thermal papers.
- Respondents allegedly facilitated the importation of over 255 million pieces of betting slips and 205,200 rolls of thermal papers from June 2005 to January 2007 without paying the corresponding duties and taxes.
- The Bureau filed a criminal complaint against the respondents under the Run After The Smugglers (RATS) Program for violations of the Tariff and Customs Code.
Facts of the Case
- MSPI imported significant quantities of finished betting slips and thermal papers for the Philippine Charity Sweepstakes Office (PCSO) operations.
- The importation took place within the jurisdiction of Manila City, specifically from the Clark Special Economic Zone.
- The Bureau of Customs alleged that the importations were unlawful due to the absence of duty and tax payments, leading to the filing of a criminal complaint.
- The State Prosecutor found probable cause, leading to the filing of Information against the respondents, citing specific violations of the Tariff and Customs Code.
Procedural History
- The respondents filed a petition for review with the Secretary of Justice while the I