Tax evasion. Non VAT return. Criminal Procedure. Res judicata infringement. Conditions of res judicata. Identity act. Conviction for failure to pay debts to the State, which debts relating to non-VAT return. Pending trial for non-performance of own VAT payments to the State. Identity Act. Indifferent the classification you give on those acts, since the facts are identical. Inadmissible prosecution because of res judicata.