THE PEOPLE OF THE PHILIPPINES, 

plaintiff-appellant, vs. GERONIMA SINDIONG DE PASTOR and

SANTOS T. PASTOR, defendants-appellees.
G.R. No. L-335         February 12, 1947

Nature of the Action: An appeal from the decision of the trial court

Facts: Defendants were charged of violating Sections 1458 and 1459 of the Revised Administrative Code, having
deliberately evaded paying the percentage tax while being owners of ‘Magazine Center’, an establishment devoted to
selling newspapers from 1936 to 1938. However, defendant Sindiong countered that the law accused of him were
repealed by CA Nos. 466 and 503, which were in force in 1939, and which excluded Sindiong’s business from the
requirement of paying taxes.

Issue: Can defendants be charged against a law that has been repealed?

Ruling: Wherefore, it is the judgment of this Court that the order appealed from be, as it is hereby, affirmed with costs de
officio.

Ratio: No. The Supreme Court held that upon the enactment of the National Internal Revenue Code (CA 466 and 503),
the defendants ceased to be bound in paying taxes. The prevailing doctrine is that where the repealing law wholly fails to
penalize the acts which constituted the offense defined and penalized in the repealed law, the repeal carries with it the
deprivation of the courts of jurisdiction to try, convict, and sentence persons charged with violations of the old law prior
to the repeal.