G.R. No. L-46881. September 15, 1988 (Case Brief / Digest)

**Title:** People of the Philippines v. Hon. Mariano Castañeda, Jr., et al.


In 1971, two informants notified the Bureau of Internal Revenue (BIR) of alleged tax violations by Francisco Valencia, Vicente Lee Teng, and Priscilla Castillo Vda. de Cura. Following investigation, criminal charges were filed in the Court of First Instance of Pampanga, leading to multiple criminal informations against the accused for violations of the National Internal Revenue Code. The case turned on the application of tax amnesty under Presidential Decree No. 370, with the accused moving to quash the charges on this basis.

Initially, Valencia’s motion was granted, effectively dismissing the charges against all accused on the premise that the dismissal for one inured to the others. The government’s motions for reconsideration were denied, and criminal cases were halted. However, seven months after the final denial, the People filed a Petition for Certiorari and Mandamus with the Supreme Court seeking annulment of the orders quashing the criminal informations.


1. Whether the People of the Philippines were guilty of laches in filing the petition.
2. If the defense of double jeopardy could be invoked by the accused following the dismissal of their cases by the lower court.
3. Whether the accused were entitled to benefits under Presidential Decree No. 370.
4. Whether the dismissal of criminal cases against Francisco Valencia inured to the benefit of his co-accused.

**Court’s Decision:**

The Supreme Court decided the People were not barred by laches and addressed the substantive legal issues directly:

1. **Laches:** The Court found that, under the circumstances, the equitable principle of laches should not bar the Petition for Certiorari and Mandamus, considering the substantive issues raised.

2. **Double Jeopardy:** The Court deemed this defense premature within the context of the certiorari proceeding, holding the validity of the dismissal orders themselves under scrutiny.

3. **Entitlement to Tax Amnesty:** The Court held that the accused were not entitled to the benefits under P.D. No. 370 due to the conditions of the amnesty not being met. Specifically, the tax cases filed prior to 31 December 1973, based on R.A. No. 2338, disqualified them from amnesty benefits. Furthermore, acceptance of tax amnesty application and payment by the BIR did not confer automatic entitlement.

4. **Effect of Dismissal on Co-Accused:** Given that Valencia was not entitled to amnesty benefits, the dismissal could not inure to the benefit of co-accused Lee Teng and Priscilla Castillo. The Court emphasized that amnesty, like any defense, is personal and cannot be automatically extended to co-conspirators.


The decision reiterated principles regarding tax amnesty applications under P.D. No. 370, specifically that eligibility must comply strictly with the decree’s conditions, and that tax cases subject to valid information under R.A. No. 2338 as of 31 December 1973 are excluded from amnesty benefits. The Court also emphasized that amnesty is a personal defense that does not extend to co-accused by virtue of conspiracy allegations.

**Class Notes:**

– **Tax Amnesty:** Strict compliance with statutory provisions is required; benefits are not extended for tax violations known to authorities and subject to prior information under R.A. No. 2338.
– **Laches:** The principle does not apply when substantive issues of significant public interest are at stake, even if there is delay in the filing of petitions.
– **Double Jeopardy:** The defense is not available in proceedings where the orders dismissing criminal charges are under legal challenge and may be set aside.
– **Personal Defense:** Defenses such as tax amnesty or insanity are personal to an accused and cannot be extended to co-accused without individual compliance with relevant statutory or procedural requirements.

**Historical Background:**

The context of this case illustrates the legal tensions between tax amnesty provisions and the prosecution of tax offenses in the Philippines. Presidential Decree No. 370 aimed to provide a broad amnesty for various tax liabilities, but it also set specific exclusions to prevent abuses. This case underscores the judiciary’s role in interpreting amnesty provisions and ensuring that such measures do not undermine the administration of justice or the enforcement of tax laws.


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