Question

Mr. Santos, a businessman, was recently charged with a criminal offense under a newly enacted law that imposes stricter penalties for tax evasion. The law states that any person found guilty of tax evasion shall be imprisoned for a minimum of 10 years and fined double the amount of the evaded taxes. Mr. Santos argues that the law should not be applied to him because his alleged offense was committed prior to the enactment of the law.

Discuss the applicability of the generality principle of penal laws under Article 14 of the Civil Code to the case of Mr. Santos. Does the new law on tax evasion, with its harsher penalties, apply to offenses committed prior to its enactment? Provide legal justifications for your answer.