The Supreme Court affirmed the Court of Tax Appeals’ (CTA) decision to acquit Jacinto C. Ligot and Erlinda Y. Ligot of tax evasion charges, emphasizing that a judgment of acquittal cannot be appealed without violating the constitutional right against double jeopardy. The Court found no grave abuse of discretion on the part of the CTA, which had determined that the prosecution failed to prove the accused’s guilt beyond a reasonable doubt. This ruling underscores the importance of adhering to procedural rules and respecting the principle that an acquittal based on the merits of the case is final and cannot be overturned absent a showing of grave abuse of discretion.

Tax Secrets and Trials: Did the Ligots Evade Justice or Face Double Jeopardy?

The case revolves around allegations that Jacinto C. Ligot and Erlinda Y. Ligot failed to accurately report their income for the taxable years 2001 through 2004, leading to charges of tax evasion under Sections 254 and 255 of the National Internal Revenue Code (Tax Code). The prosecution asserted that the couple had undeclared income, evidenced by various real and personal properties acquired during the relevant periods. However, the CTA acquitted the accused-respondents, leading the People of the Philippines, represented by the Bureau of Internal Revenue (BIR), to file a petition for certiorari, arguing grave abuse of discretion on the part of the CTA.

The central legal question is whether the CTA acted with grave abuse of discretion in acquitting the Ligots, and whether such acquittal could be reviewed without violating the principle of double jeopardy. The Supreme Court addressed the procedural aspects of the case, including the hierarchy of courts, which dictates that appeals from CTA Divisions should first be brought before the CTA En Banc. The Court then delved into the substantive issue of whether the CTA’s decision was tainted by grave abuse of discretion.

The Supreme Court emphasized the constitutional prohibition against double jeopardy, as enshrined in Section 21 of Article III of the Constitution:

SECTION 21. No person shall be twice put in jeopardy of punishment for the same offense. If an act is punished by a law and an ordinance, conviction or acquittal under either shall constitute a bar to another prosecution for the same act.

Double jeopardy arises when there is a valid complaint, a court of competent jurisdiction, the defendant pleaded to the charge, and the defendant was acquitted or convicted. However, an acquittal can be reviewed via a special action for certiorari under Rule 65 if the trial court acted with grave abuse of discretion amounting to lack or excess of jurisdiction. It is crucial to distinguish between errors of judgment and errors of jurisdiction. An error of judgment, such as the evaluation of evidence, cannot be remedied by certiorari.

In this case, the prosecution primarily questioned the CTA’s appreciation of evidence regarding the Ligots’ alleged undeclared income. The CTA found that the prosecution failed to sufficiently establish the accused-respondents’ ownership over several properties, including the Piana Properties, Paseo Parkview Tower II Properties, and the Toyota Hilux. The court noted deficiencies in the documentary evidence presented, such as the lack of authentication of tax declarations and the failure to present original documents as required by the Best Evidence Rule.

Regarding the Tanay Property, the CTA concluded that an implied trust existed between Jacinto and his co-buyers. Even though Jacinto did not declare his undivided share in his Statement of Assets, Liabilities, and Net Worth (SALN), the evidence did not conclusively prove that he paid for the entire property with undeclared income. The CTA’s decision hinged on its assessment of the evidence presented and its determination that the prosecution failed to prove the Ligots’ guilt beyond a reasonable doubt.

The Supreme Court deferred to the CTA’s findings, stating that when there is no allegation or proof of mistrial, there is no need to re-examine the evidence. Allowing a re-examination would amount to permitting an appeal on an acquittal, which violates the accused’s right against double jeopardy. The Court emphasized that certiorari cannot be used as a substitute for an appeal.

Several critical pieces of evidence were excluded or given little weight by the CTA. This included an AMLC Investigation Report and testimony from an AMLC officer due to bank secrecy laws, such as Republic Act No. 1405, RA 6426 and RA 8367. The CTA held that the exceptions to these bank secrecy laws do not extend to tax evasion cases. This underscored the tension between the government’s need to investigate financial crimes and the individual’s right to privacy and protection against self-incrimination.

The Supreme Court also addressed the procedural misstep of filing the petition directly with the Supreme Court instead of the CTA En Banc. Section 2(f), Rule 4 of the Revised Rules of the Court of Tax Appeals dictates that the CTA En Banc has exclusive appellate jurisdiction over decisions of the CTA Division involving criminal offenses arising from violations of the NIRC. The Court clarified that this appellate jurisdiction includes the power to issue writs of certiorari. Despite this procedural error, the Court proceeded to address the merits of the case, ultimately affirming the CTA’s decision.

The Supreme Court cited the principle that “Where the law does not distinguish, we should not also distinguish. Ubi lex non distinguit, nec nos distinguere debemus.” The Court found no reason to exclude criminal cases from the certiorari jurisdiction of the CTA En Banc. Thus, the Supreme Court underscored the importance of adhering to the principle of hierarchy of courts, which promotes the orderly administration of justice and prevents the Supreme Court from being burdened with cases that could be resolved at a lower level.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Tax Appeals (CTA) committed grave abuse of discretion in acquitting Jacinto C. Ligot and Erlinda Y. Ligot of tax evasion charges, and whether the Supreme Court could review the acquittal without violating the principle of double jeopardy.
What is the principle of double jeopardy?	Double jeopardy means a person cannot be tried twice for the same offense if they have already been acquitted or convicted. This protection is enshrined in the Philippine Constitution to prevent repeated prosecutions for the same crime.
What is a petition for certiorari?	A petition for certiorari is a special civil action filed to correct errors of jurisdiction committed by a lower court. It is generally not a substitute for an appeal, but it can be used to review a judgment of acquittal if the trial court acted with grave abuse of discretion.
What constitutes grave abuse of discretion?	Grave abuse of discretion means the lower court acted in a capricious, whimsical, or arbitrary manner, amounting to a lack or excess of jurisdiction. It is more than just an error of judgment; it involves a blatant disregard of the law or established jurisprudence.
Why did the Supreme Court uphold the acquittal in this case?	The Supreme Court upheld the acquittal because it found that the CTA did not commit grave abuse of discretion. The CTA had carefully considered the evidence and determined that the prosecution failed to prove the accused’s guilt beyond a reasonable doubt.
What is the role of the Court of Tax Appeals (CTA) En Banc in this case?	The CTA En Banc has exclusive appellate jurisdiction over decisions of the CTA Division involving criminal offenses arising from violations of the National Internal Revenue Code (NIRC). The Supreme Court noted that the petition for certiorari should have been filed first with the CTA En Banc.
What are the bank secrecy laws mentioned in the case?	The bank secrecy laws mentioned include Republic Act No. 1405 (Secrecy of Bank Deposits Act), RA 6426 (Foreign Currency Deposit Act), and RA 8367 (Revised Non-Stock Savings and Loan Association Act). These laws generally protect the confidentiality of bank deposits.
What was the prosecution’s main argument for claiming tax evasion?	The prosecution argued that the accused-respondents had undeclared income, evidenced by various real and personal properties acquired during the relevant periods, which were disproportionate to their declared income in their Income Tax Returns (ITRs).

The Supreme Court’s decision in this case reinforces the constitutional protection against double jeopardy and underscores the importance of adhering to procedural rules in tax evasion cases. While the government has a legitimate interest in prosecuting tax evaders, it must do so in a manner that respects the rights of the accused and avoids placing them in double jeopardy. The ruling also highlights the balance between the need to investigate financial crimes and the individual’s right to privacy and protection against self-incrimination.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: PEOPLE OF THE PHILIPPINES, VS. COURT OF TAX APPEALS – THIRD DIVISION, JACINTO C. LIGOT AND ERLINDA Y. LIGOT, G.R. Nos. 250736 and 250801-03, December 05, 2022