Question

Mr. Santos created a new business venture and decided to open a retail store selling electronic gadgets. He imported several units of the latest smartphone model and displayed them in his store for sale. It was at this time that he came across a news article stating that a new tax law affecting the importation and sale of electronic gadgets has been enacted by the Philippine Congress.

Unsure about the specifics of the new tax law, Mr. Santos seeks legal advice on whether he can still be liable for the new tax imposed by the law even though he imported and displayed the smartphones in his store prior to the law's publication in a newspaper of general circulation.

Question:

Based on the Civil Code provision on when a law takes effect through publication, discuss the effect and application of the new tax law on Mr. Santos' importation and sale of smartphones. Will Mr. Santos still be liable for the tax imposed by the new law despite importing the gadgets before its publication? Explain your answer.