Back

People vs. Tiotangco

PEOPLE OF THE PHILIPPINES, PETITIONER, VS. REBECCA S. TIOTANGCO, RESPONDENT.

G.R. No. 264192 | 2023-11-13

D E C I S I O N
 
LOPEZ, M., J.:
 
Once again, we encounter the question of whether a final assessment is necessary to a judgment for civil liability for unpaid taxes in the same criminal action for violation of tax laws. Indeed, this Court is aware that in various tax­related criminal actions filed before the Court of Tax Appeals (CTA), the CTA ruled on the innocence or guilt of the taxpayer-accused but without a finding for the civil liability for taxes due to the absence of a formal assessment from the Commissioner of Internal Revenue (CIR). In this case, we reiterate that a final decision on disputed assessment is not a...