Sumbilla v. Matrix Finance
REITERATIONFacts
The Antecedents: Petitioner Julie S. Sumbilla obtained a cash loan from respondent Matrix Finance Corporation and issued six post-dated checks (Philippine Business Bank Check Nos. 0032863 to 0032868, each with a face value of ₱6,667.00) as partial payment. Upon maturity, the checks were dishonored due to being drawn against a closed account. Petitioner's refusal to pay led to her indictment for six counts of violation of Batas Pambansa Blg. 22 (BP 22). Procedural History: The Metropolitan Trial Court (MeTC) found petitioner guilty for six counts of violation of BP 22 and imposed a fine of ₱80,000.00 for each count, with subsidiary imprisonment in case of non-payment. Her civil liability was fixed at ₱40,002.00. Petitioner filed a Motion for Reconsideration instead of an appeal, which was denied. Her subsequent Notice of Appeal was also denied for being filed out of time. A petition for certiorari before the Regional Trial Court (RTC) was dismissed for lack of grave abuse of discretion by the MeTC. The Court of Appeals (CA), in turn, ruled that an ordinary appeal, not a petition for certiorari, was the proper remedy, and denied petitioner's motion for reconsideration. The Petition: Petitioner filed a petition for review on certiorari before the Supreme Court, acknowledging her procedural lapses but seeking the modification of the penalty imposed by the MeTC, arguing it was excessive and contrary to law and jurisprudence. She contended that the fine of ₱80,000.00 per count was beyond the maximum penalty prescribed by BP 22, which should only be double the face value of the check (₱13,334.00), and that subsidiary imprisonment was improperly imposed.
Issue(s)
Whether the penalty imposed by the MeTC for violation of BP 22 may be modified despite the finality of the judgment. Whether the penalty of ₱80,000.00 fine per count for violation of BP 22, involving checks with a face value of ₱6,667.00, is excessive and contrary to law. Whether subsidiary imprisonment is a valid imposition for non-payment of the fine in BP 22 cases, considering Administrative Circular Nos. 12-2000 and 13-2001, and the ruling in Vaca v. Court of Appeals.
Ruling
The petition is granted. The MeTC Decision is modified. The fine imposed on petitioner is corrected to ₱13,334.00 for each count.
Ratio Decidendi
On the modification of a final and executory judgment: The Court acknowledged the general rule of immutability of judgments, which bars modification of final decisions. However, it emphasized that this rule is not absolute and can be suspended in the interest of substantial justice. The Court cited several cases where it relaxed procedural rules to correct erroneous penalties that were outside the legal range, even after finality, to prevent a miscarriage of justice. The Court noted that procedural rules are tools to aid justice, and their strict application should be avoided if it hinders substantial justice. The Court found that the present case warranted such relaxation due to the clear error in the penalty imposed. On the excessiveness of the penalty: The Court meticulously examined Section 1 of Batas Pambansa Blg. 22 (BP 22). It clarified that the law provides for imprisonment of not less than 30 days but not more than one year, or a fine of not less than but not more than double the amount of the check (not exceeding ₱200,000.00), or both. For a fine alone, the maximum is double the face value of the check, which in no case shall exceed ₱200,000.00. In this case, the face value of each check was ₱6,667.00. Therefore, the maximum fine imposable per count should have been ₱13,334.00 (double the face value). The MeTC's imposition of ₱80,000.00 per count was found to be significantly beyond this prescribed limit, constituting an erroneous computation based on the total face value of all checks rather than each individual check. On subsidiary imprisonment and administrative issuances: The Court addressed the petitioner's concern regarding subsidiary imprisonment and its relation to Administrative Circular Nos. 12-2000 and 13-2001, and the Vaca v. Court of Appeals ruling. It quoted Administrative Circular No. 13-2001, which clarified that Administrative Circular No. 12-2000 did not remove imprisonment as an alternative penalty for BP 22 violations, nor did it preclude the application of subsidiary imprisonment if a fine was imposed and the accused was unable to pay it. The Court also reiterated the ruling in Lozano v. Martinez, which held that BP 22 does not violate the constitutional prohibition against imprisonment for debt, as the offense punished is the act of issuing a worthless check, not the non-payment of an obligation. Therefore, the imposition of subsidiary imprisonment was not inherently illegal.
Main Doctrine
While the doctrine of immutability of judgments ordinarily bars modification of a final and executory decision, the Supreme Court may suspend its own rules and exempt a case from their operation when justice requires it, particularly to correct erroneous penalties that are clearly out of the range prescribed by law, in the interest of substantial justice.