Primary Holding

The Supreme Court ruled that the repeal of Circular No. 960 did not extinguish petitioners' criminal liability as saving clauses preserved pending cases. It also held that jurisdiction was proper in the Regional Trial Court (RTC), and claims of prescription, exemption, and immunity were unmeritorious.

Background

The case arose from multiple criminal charges filed against Benedicto and Rivera for failing to report foreign exchange earnings as required by Central Bank Circular No. 960. The petitioners argued that their liability was extinguished due to the circular's repeal and other defenses such as prescription and immunity under a compromise agreement with the government.

Facts

• 1. Petitioners were charged with failing to report foreign exchange earnings from accounts abroad between 1983 and 1987.
• 2. The charges stemmed from alleged violations of Central Bank Circular No. 960 in relation to Section 34 of Republic Act No. 265.
• 3. Petitioners argued that their liability was extinguished by subsequent circulars repealing Circular No. 960 and by a compromise agreement granting them immunity.

Arguments of the Petitioners

• 1. Lack of jurisdiction by the RTC; cases should fall under Sandiganbayan jurisdiction.
• 2. Extinction of liability due to: (1) Repeal of Circular No. 960. (2) Prescription under Act No. 3326.
• 3. Exemption from reporting requirements under Circular No. 960.
• 4. Absolute immunity granted under a compromise agreement with the government.

Arguments of the Respondents

• 1. Jurisdiction was proper under Presidential Decree No. 1606 because violations carried penalties below six years' imprisonment.
• 2. Saving clauses in subsequent circulars preserved pending cases despite repeal.
• 3. Prescription did not apply as offenses were discovered only after February 1986 following the EDSA Revolution.
• 4. Petitioners failed to meet requirements for exemption or prove immunity covered these cases.

Issues

• 1. Did the RTC have jurisdiction over the cases?
• 2. Did the repeal of Circular No. 960 extinguish criminal liability?
• 3. Had prescription barred prosecution?
• 4. Were petitioners exempted from reporting requirements?
• 5. Did petitioners have immunity under a compromise agreement?

Ruling

• 1. The Supreme Court ruled in favor of respondents
• 2. Jurisdiction: RTC had jurisdiction as violations carried penalties below six years' imprisonment.
• 3. Repeal and Saving Clauses: Repeal did not extinguish liability due to saving clauses in Circular Nos. 1318 and 1353.
• 4. Prescription: Prescription began in February 1986 when offenses were discovered; cases filed in 1991-1992 were timely.
• 5. Exemption: Petitioners failed to prove they qualified for exemptions under Circular No. 960 or Republic Act No. 6426.
• 6. Immunity: Compromise agreement did not cover these criminal cases.

Doctrines

• 1. Saving Clause Doctrine: Repealed laws may retain effect for pending actions if a saving clause is included.
• 2. Prescription Under Special Laws (Act No. 3326): Prescription begins upon discovery if offenses were concealed.
• 3. Jurisdiction Determination Rule: Jurisdiction is determined by penalties prescribed at the time cases are filed.

Precedents Cited

• 1. People v. Moran – Penal laws operate prospectively unless favorable to accused.
• 2. Bataan Shipyard v. PCGG – Judicial notice taken on schemes disguising illicit acquisitions during Marcos regime.

Statutory and Constitutional Provisions

• 1. Central Bank Act (R.A. No. 265), Section 34 – Penal provision for violations.
• 2. Revised Penal Code, Article 22 – Retroactive application of penal laws favorable to accused.
• 3. Constitution, Article III, Section 22 – Prohibition against ex post facto laws.