PEOPLE OF THE PHILIPPINES v. LEONIDES LIBUNAO LIGON 220-C B Esguerra St., Balatong B Pulilan, Bulacan and Scuala, Barangay San Juan, San Miguel, Bulacan

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY THIRD DIVISION PEOPLE OF THE CTA Crim. Case No. 0-1019 Members: PHILIPPINES, Plaintiff -versus- MANAHAN, Chairperson, REYES-FAJARDO, and ANGELES, fl. Promulgated: LEONIDES LIBUNAO LIGON, Accused. x---------------------------------------------------x RESOLUTION First-off, we note the National Bureau of Investigation's Rett1rn of the Warrant of Arrest with Prayers, submitted on May 27, 2024, stating among others that: (1) its operatives went twice on 220-C B. Esguerra St., Balatong B, Pulilan, Bulacan, and was informed by the Office of Barangay Balatong B that accused is neither known, nor a resident of said barangay; (2) its operatives went to Scuala, Barangay San Juan, San Miguel Bula~an, and was informed by the barangay tanod that Leonides Libunao Ligon died sometime in 2021; and (3) his daughter Lady Ann Pamular Ligon confirmed her father's death on May 3, 2021, as evidenced by a certified copy of Leonides Libunao Ligon's Death Certificate. Next, the 1997 National Internal Revenue Code, as amended is silent, as to the effect of the alleged perpetuator's death on the tax offense charged. In this regard, Article 101 of the Revised Penal Code Article 10. Offenses 110t subject to the provisions of this Code. - Offenses which are or in the future may be punishable under special laws are not subject to the provisions of this Code. This Code shall be supplementary to such laws, unless the latter should specially provide the contrary.

RESOLUTION CTA Crim. Case No. 0-1019 (RPC),2 as amended, permits the suppletory application of its provisions to the instant case. Specifically, among the circumstances when there is total loss of criminal liability is found under Article 89(1) of the RPC, as amended, which states: Article 89. How criminal liability zs totally extinguished. - Criminal liability is totally extinguished: 1. By the death of the convict, as to the personal penalties and as to pecuniary penalties, liability therefor is extinguished only when the death of the offender occurs before final judgment. As observed earlier, accused Leonides Libunao Ligon died on May 3, 2021.3 Following Article 89(1) of the RPC, as amended, there is total extinction of his criminal liability; hence, dismissal of CTA Crim. Case No. 0-1019 is warranted. WHEREFORE, we RESOLVE to: a. NOTE and ACCEPT, the National Bureau of Investigation's Return of the Warrant of Arrest with Prayers, submitted on May 27, 2024; b. WITHDRAW from the archives, CTA Crim. Case No. 0-1019; and c. DISMISS CTA Crim. Case No. 0-1019, due to the death of Leonides Libunao Ligon. SO ORDERED. C~ 7 ~ CATHERINE T. MANAHAN Associate Justice 2 Act No . 3815. 3 Death Certificate of Leonides Libunao Ligon. Annex "D," Return Warrant of Arrest with Prayers. Docket, unpaginated.

RESOLUTION CTA Crim. Case No. 0-1019 ~ IaVJ\U~ Ft. R~-F-At)it'ii~RJDvO MARIAN Associate Justice HENRY /l}NGELES Associate Justice