People v. Chu Chi
REITERATIONFacts
The Antecedents: Felipe Umlas purchased a fresh duck's egg from the store of defendant-appellant Chu Chi for P0.20. A patrolman, Josue del Rosario, assigned to the price control unit, overheard the transaction and inquired about the price. Upon learning that Umlas paid P0.20, del Rosario checked the price list and found that the ceiling price for a duck's egg was P0.15. Chu Chi, when confronted, claimed ignorance of the current ceiling price. Procedural History: Both Umlas and Chu Chi were taken to the police station, where Chu Chi signed a statement admitting the sale of the egg for P0.20. The Court of First Instance of Manila found Chu Chi guilty of violating Executive Order No. 331 in relation to Republic Act No. 509, sentencing him to a fine of P5,000, with subsidiary imprisonment in case of insolvency, cancellation of his license, a five-year business ban, and recommended deportation. The case was appealed to the Court of Appeals, which certified it to the Supreme Court due to the appellant questioning the constitutionality of the law. The Petition: The defendant-appellant contended that the trial court erred in not giving weight to his testimony denying the sale and claiming it was his salesgirl who made the transaction. He also argued that Republic Act No. 509 is unconstitutional due to the imposition of an excessive fine.
Issue(s)
Whether the trial court erred in giving weight and credit to the prosecution's evidence over the defendant-appellant's denial. Whether Republic Act No. 509 is unconstitutional for imposing an excessive fine.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance of Manila in all other respects, except for the penalty imposed. The fine of P5,000 was reduced to P2,000, with subsidiary imprisonment in case of insolvency. The conviction for violation of Executive Order No. 331 in relation to Republic Act No. 509 was upheld.
Ratio Decidendi
On the issue of credibility of evidence: The Court found the defendant-appellant's claim to be without merit. His testimony was uncorroborated. Conversely, the prosecution's theory was supported by the testimony of Felipe Umlas, the buyer, who identified the defendant-appellant as the seller. Furthermore, the defendant-appellant admitted the sale to the policeman and explained his ignorance of the ceiling price. This admission, coupled with his subsequent signing of the statement (Exhibit A) at the police station, further corroborated the prosecution's version of the events. The trial court's refusal to credit the denial was therefore justified. On the constitutionality of Republic Act No. 509: The Court held that Republic Act No. 509 is not necessarily unconstitutional for imposing a fine of not less than P2,000 nor more than P10,000 for selling an article in excess of the ceiling price. Citing its own recent decision in People vs. De la Cruz, the Court reiterated that such a penalty is not inherently excessive. However, in the interest of justice and to ensure the penalty is commensurate with the gravity of the offense, the Court exercised its power to reduce the penalty imposed by the trial court. The P5,000 fine was reduced to P2,000, with subsidiary imprisonment in case of insolvency, aligning with the principle that penalties should be proportionate to the crime.
Main Doctrine
The penalty imposed for violation of price control laws, specifically Republic Act No. 509, must be commensurate with the gravity of the offense. While the law itself is not necessarily unconstitutional for imposing a fine of not less than P2,000 nor more than P10,000, the Supreme Court may reduce the imposed penalty if deemed excessive, applying subsidiary imprisonment in case of insolvency.