GR 208290; (December, 2013) (Digest)
G.R. No. 208290 ; December 11, 2013
PEOPLE OF THE PHILIPPINES, Petitioner, vs. THE HONORABLE JUANITO C. CASTANEDA, JR., HONORABLE CAESAR A. CASANOVA, HONORABLE CIELITO N. MINDARO-GRULLA, AS ASSOCIATE JUSTICES OF THE SPECIAL SECOND DIVISION, COURT OF TAX APPEALS; and MYRNA M. GARCIA AND CUSTODIO MENDOZA VESTIDAS, JR., Respondents.
FACTS
Private respondents Myrna M. Garcia and Custodio Mendoza Vestidas, Jr. were charged before the Court of Tax Appeals (CTA) with violation of the Tariff and Customs Code for allegedly fraudulently importing 858 cartons of anti-virus software by misdeclaring the shipment as CD kit cleaners and plastic CD cases, resulting in a substantial loss of customs duties for the government. After pleading not guilty and undergoing pre-trial, the prosecution presented witnesses who testified on the physical examination of the container van and the electronic filing process. The prosecution subsequently filed its formal offer of evidence.
The respondents filed a Demurrer to Evidence, arguing that the prosecution failed to prove their guilt beyond reasonable doubt. They contended that the documentary evidence was inadmissible, the alleged misdeclared goods were not presented in court, and none of the prosecution witnesses positively identified the accused as responsible for the misdeclaration. The CTA granted the demurrer and dismissed the case, finding the evidence insufficient.
ISSUE
Whether the CTA committed grave abuse of discretion in granting the Demurrer to Evidence and dismissing the criminal case against the respondents.
RULING
The Supreme Court upheld the CTA’s dismissal. The legal logic centers on the prosecution’s failure to meet the quantum of proof required in criminal cases and the consequent absence of grave abuse of discretion by the CTA. The prosecution’s evidence was fundamentally flawed. The certified true copies of public documents, such as the import entry and bill of lading, were not properly authenticated by the legal custodian as required by the Rules of Court. These documents were thus inadmissible as evidence. Furthermore, the prosecution admitted that the alleged misdeclared goods were never presented and properly identified in court, and that no witness positively identified the accused. These fatal evidentiary gaps meant the prosecution did not establish a prima facie case. Consequently, the CTA’s grant of the demurrer was a correct exercise of its judicial discretion, not an arbitrary or capricious act amounting to grave abuse. The Court also noted the petition was filed out of time, and no compelling reason justified relaxing procedural rules. The dismissal placed the respondents in double jeopardy, barring a revival of the case.