Practice question
An agency could readily identify a taxpayer’s unfiled return when the statutory filing deadline passed because its own reporting and electronic records supplied the relevant information. It waits years, then calls its later internal review the first discovery and claims a fresh full limitation period. What does Consebido require?
- A later internal review always restarts prescription
- The agency may select any discovery date
- Examine whether the violation was already reasonably knowable; the later asserted discovery does not automatically control
- A complaint filed after prescription necessarily revives the offense
- Tax offenses are exempt from prescription
Legal references
- People v. Consebido, G.R.258563, April2 2025, main decision, discovery analysis: https://lawphil.net/judjuris/juri2025/apr2025/gr_258563_2025.html
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