PEOPLE OF THE PHILIPPINES v. NICHOLSON C. SANTOS JOSEPHINE CHEN

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS Quezon City SECOND DIVISION PEOPLE OF THE CTA Crim. Case No. 0-901 PHILIPPINES, For: Violation of Section 254 in Plaintiff, relation to Sections 253(d) and 256 -versus- of the National Internal Revenue Code of 1997, as amended (Attempt to Evade or Defeat Tax) Members: CASTANEDA, JR. , Chairperson, BACORRO-VILLENA, and FJORD INTERNATIONAL CUI-DAVID, JJ. CORPORATION and its responsible officers, NICHOLSON C. SANTOS 27 Promulgated: / and JOSEPHINE CHEN, FEB 09 Accused. X- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X ) J: n ,.,. . RESOLUTION In this Court's 19 October 2021 Resolution , it ordered Prosecution Attorney Josenino M. Garcia (Prosecution Attorney Garcia) of the Department of Justice (DOJ) to submit the original or certified true copy of the subpoena issued to accused Nicholson C. Santos and Josephine Chen. On 06 December 2021 , Prosecution Attorney Garcia filed his Compliance and the same is accordingly NOTED. However, upon evaluation of the prosecutor's resolution and the supporting evidence for the crime charged , the Court found that the annexes attached to the Joint Complaint-Affidavit executed by Revenue Officers Rachelle 0. Villanueva and Rene Dr. Catindig refer to a different entity, i.e., Antonio Maceda Integrated School , and thus, cannot be considered as basis for the determination of probable cause for the issuance of a warrant of arrest against the responsible officers of accused Fjord International Corporation.

RESOLUTION CTA. CRIM . CASE NO. .D..:..2..0..1 People v. Fjord International Corporation and its res ponsible officers, Nicholson C. Santos an d josephine Chen Page 2 of2 X� � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � X WHEREFORE, the instant Information is DISMISSED, without prejudice to the re-filing of the same with complete and correct supporting documents (on which the determination of probable cause wi ll be based ). SO ORDERED. J- s;l~t:C . ~c:4.; JUANITO C. CASTANEDA, JR. Associate Justice ~~ LANEE S. CUI-DAVID Associate Justice