Santos v. People
REITERATIONFacts
The Antecedents: The Bureau of Internal Revenue (BIR) recommended the criminal prosecution of petitioner Judy Anne L. Santos for substantial underdeclaration of income for taxable year 2002, constituting prima facie evidence of a false or fraudulent return under Section 248(B) of the National Internal Revenue Code (NIRC), as amended. The BIR found that Santos declared an income of P8,033,332.70, while evidence indicated she received at least P14,796,234.70 from various sources, resulting in an estimated tax liability of P1,718,925.52, including penalties. The Department of Justice (DOJ) found probable cause and filed an Information with the CTA for violation of Section 255, in relation to Sections 254 and 248(B) of the NIRC. Procedural History: Petitioner filed a Motion to Quash the Information with the CTA First Division, raising grounds including the facts not constituting an offense, lack of authority of the filing officer, lack of CTA jurisdiction, and violation of due process and equal protection. The CTA First Division denied the motion. Petitioner then filed a Motion for Reconsideration, which was also denied. Subsequently, petitioner filed a Motion for Extension of Time to File Petition for Review with the CTA en banc, which was also denied, holding that a resolution denying a motion to quash is an interlocutory order and not a proper subject of appeal. The Petition: Petitioner filed a Petition for Review on Certiorari with the Supreme Court, assailing the CTA en banc's Resolution denying her Motion for Extension of Time to File Petition for Review. The sole issue presented was whether a resolution of a CTA Division denying a motion to quash is a proper subject of an appeal to the CTA en banc under Section 11 of Republic Act No. 9282.
Issue(s)
Whether a resolution of a CTA Division denying a motion to quash is a proper subject of an appeal to the CTA en banc under Section 11 of Republic Act No. 9282. Whether the CTA First Division committed grave abuse of discretion in denying petitioner’s Motion to Quash, considering the alleged lack of authority of the filing officer, denial of due process and equal protection, and other grounds raised by the petitioner.
Ruling
The Supreme Court denied the Petition for Review. It held that the CTA en banc did not err in denying petitioner’s Motion for Extension of Time to File Petition for Review because a resolution denying a motion to quash is an interlocutory order and thus unappealable. Even if treated as a petition for certiorari, it was dismissible for lack of merit.
Ratio Decidendi
On the appealability of a denial of a motion to quash: The Court reiterated the general rule that a resolution denying a motion to quash is an interlocutory order, which is not immediately appealable. Such an order does not finally dispose of the case but leaves substantial proceedings to be had. The remedy for the accused is to proceed with the trial and, if an adverse decision is rendered, to appeal therefrom. The Court clarified that the CTA en banc's appellate jurisdiction under Section 18 of Republic Act No. 1125, as amended, is limited to decisions or resolutions on motions for reconsideration or new trial, not interlocutory orders like the denial of a motion to quash. The Court emphasized that allowing appeals from interlocutory orders would lead to multiplicity of appeals and undue delays in the administration of justice. While the general rule prohibits appeals of interlocutory orders, the Court acknowledged exceptions where special circumstances demonstrate the inadequacy of appeal. These include instances of grave abuse of discretion, patent error, or when the order is rendered without or in excess of jurisdiction. In such exceptional cases, a special civil action for certiorari may be allowed. The Court noted that the Revised Rules of Court explicitly allows for an appropriate special civil action under Rule 65 when a judgment or final order is not appealable. However, the Court found no such exceptional circumstances in the present case to warrant certiorari. On the CTA First Division's denial of the Motion to Quash: The Court concluded that the CTA First Division did not commit grave abuse of discretion in denying petitioner's Motion to Quash. The Court found no merit in petitioner's claim that the Information was filed without the approval of the BIR Commissioner. BIR Commissioner Parayno's letter to the DOJ Secretary, referring the case for preliminary investigation and filing of an information if warranted, constituted sufficient prior approval as required by Section 220 of the NIRC. The Court also clarified that the DOJ, through its State Prosecutors, has the authority to file informations before the CTA, which has exclusive original jurisdiction over tax-related criminal offenses, and this authority is not superseded by the Quezon City Prosecutor's office. The Court held that petitioner was not denied due process as she was afforded the opportunity to be heard during the preliminary investigation. The Court also found no denial of equal protection. Petitioner failed to establish that she and Regina Encarnacion A. Velasquez were similarly situated and treated differently. The Court stressed that the prosecution of one guilty person while others are not does not, by itself, constitute a denial of equal protection unless there is clear and intentional discrimination, which was not shown here. The Court also noted that the remedy for unequal enforcement of the law is not the exoneration of the guilty but addressing the discriminatory practice itself. The grounds raised by the petitioner were either not evident on the face of the information or were adequately addressed by the CTA. The resolutions denying the motion were reasoned and did not reflect a capricious or arbitrary exercise of judgment.
Main Doctrine
A resolution denying a motion to quash is an interlocutory order and is not immediately appealable to the Court of Tax Appeals (CTA) en banc. The proper remedy is to proceed with trial and appeal any adverse decision thereafter. Recourse to a petition for certiorari may be allowed in exceptional circumstances involving grave abuse of discretion.