Non Bis In Idem in Successive Customs Declarations

An individual, having been convicted in a prior proceeding for failing to declare certain goods upon import, subsequently faced criminal charges for failing to declare the same goods when they were brought into the country for the second time under a different customs regime. The court of cassation quashed the lower court's decision because the prior conviction for non-declaration under one customs regime constituted a final judgment on the *fact* of non-declaration concerning those specific goods, thereby barring subsequent prosecution for the same act under the second regime due to the principle of *non bis in idem*, as the subsequent offense merely repeated the same illicit conduct already adjudicated.