People v. Bongcac
REITERATIONFacts
The Antecedents: The Mayor of Tagbilaran City designated petitioner Panfilo D. Bongcac as his representative to the City Market Committee, Consultant on market matters, and adviser to the Acting Market Administrator. Respondents Engr. Fortunato Lim and Toribio Bon applied for market stalls and were referred to petitioner. Petitioner showed them the minutes of a meeting awarding them stalls and informed them that if they were interested, they should provide additional funds for stall construction. Lim issued a check for ₱62,000, and Bon issued checks for ₱30,000 and ₱10,000 to petitioner, who issued handwritten receipts. Petitioner assured them the stalls would be completed by specific dates. The checks were encashed. Procedural History: Lim and Bon later learned that petitioner was dismissed from his positions. They demanded an accounting of the money or delivery of the stalls, which petitioner failed to provide. Consequently, petitioner was charged with two counts of Estafa under Article 315, 1(b) of the Revised Penal Code before the Sandiganbayan. The Sandiganbayan found petitioner guilty beyond reasonable doubt and sentenced him to suffer indeterminate penalties and to indemnify the complainants. Petitioner moved for reconsideration, which was denied. He then filed a petition for review on certiorari with the Supreme Court (G.R. Nos. 149711-12), which was denied for failure to show reversible error and extraordinary circumstances. This resolution became final and executory. Subsequently, the Sandiganbayan issued a notice for execution of judgment. Petitioner filed an "Extraordinary Petition" with the Supreme Court, seeking to reverse the Sandiganbayan decision and declare his acquittal. He also filed a motion with the Sandiganbayan to suspend proceedings pending the resolution of his extraordinary petition. The Sandiganbayan denied this motion and ordered his arrest, cancelling his bailbond. The Supreme Court denied the "Extraordinary Petition." Petitioner then filed the present petition for certiorari and prohibition. The Petition: Petitioner filed the present petition for certiorari and prohibition, praying that the Sandiganbayan's Resolution denying his motion to hold execution in abeyance be set aside, and that the bench warrant and cancellation of his bailbond be recalled. He also sought to suspend the execution of the Sandiganbayan Decision.
Issue(s)
Whether the Sandiganbayan acted with grave abuse of discretion, amounting to lack of jurisdiction, in denying petitioner’s motion to hold in abeyance the execution of judgment. Whether the cancellation of petitioner's cash bailbond was proper.
Ruling
The petition is dismissed. The Resolution dated 10 January 2003 of the Sandiganbayan in Criminal Case Nos. 18005 and 18006 is affirmed. Costs against petitioner.
Ratio Decidendi
On the denial of the motion to hold execution in abeyance: The Court held that the Sandiganbayan did not commit grave abuse of discretion. The petitioner's appeal of the Sandiganbayan's decision (G.R. Nos. 149711-12) was denied by the Supreme Court, and this denial became final and executory. Consequently, the Sandiganbayan's decision of conviction also became final and executory. The principle of immutability of final judgment dictates that once a judgment has become final, it can no longer be amended, modified, or reversed, except for clerical errors or void judgments. The Court emphasized that litigation must end, and the winning party should not be deprived of the fruits of the verdict through mere subterfuge. The petitioner's subsequent filings, including the "Very Urgent Petition for Extraordinary Relief," were deemed dilatory tactics to delay the execution of the final judgment. The Court reiterated that execution of a final judgment is the "fruit and end of the suit," and courts must guard against schemes that frustrate this process. Therefore, the Sandiganbayan's denial of the motion to suspend execution was a ministerial duty and not an act of grave abuse of discretion. On the cancellation of the bailbond: The Court affirmed the Sandiganbayan's order cancelling the petitioner's cash bailbond. Section 22 of Rule 114 of the Revised Rules of Criminal Procedure explicitly states that bail shall be deemed automatically cancelled upon the execution of the judgment of conviction. Since the judgment of conviction had become final and executory, its execution was ministerial, and the cancellation of the bailbond was a necessary consequence of this execution. The Sandiganbayan did not err in ordering the cancellation of the bailbond as it was in accordance with the rules and the finality of the judgment.
Main Doctrine
The Sandiganbayan did not commit grave abuse of discretion in denying the petitioner's motion to hold in abeyance the execution of judgment, as the judgment of conviction had already become final and executory. The principle of immutability of final judgment dictates that once a judgment becomes final, it can no longer be amended or altered, and its execution becomes a ministerial duty of the court. Furthermore, the cancellation of the bailbond is automatic upon the execution of the judgment of conviction.