People v. Court of Tax Appeals-Third Division

Summary

The People of the Philippines charged spouses Jacinto and Erlinda Ligot with tax evasion under NIRC Sections 254 and 255 for taxable years 2001-2004, alleging they failed to declare income totaling hundreds of millions of pesos while reporting only minimal compensation income. The CTA Third Division acquitted them, finding that key evidence including AMLC reports and bank records were inadmissible under bank secrecy laws, and that the prosecution failed to properly authenticate property ownership evidence. The Supreme Court dismissed the People's certiorari petition, ruling it should have been filed with the CTA En Banc first under the hierarchy of courts principle. The Court found no grave abuse of discretion, emphasizing that questioning evidence appreciation constitutes an error of judgment, not jurisdiction, and that acquittals are protected by double jeopardy. The case demonstrates the intersection of criminal prosecution, tax law, and procedural requirements, particularly regarding bank secrecy protections and evidence authentication in tax evasion cases.