Navarra v. People
REITERATIONFacts
The Antecedents: Petitioner Jorge B. Navarra was charged with violation of Section 22 (a), in relation to Section 28 (h) and (f), of Republic Act No. (RA) 8282 for allegedly failing to remit SSS contributions and loan payments withheld from employees of Far East Network of Integrated Circuits Subcontractors (FENICS) Corporation, where he was President and Chairman of the Board, from July 1997 to June 2000. The total unpaid obligations amounted to P10,077,656.24. Procedural History: The Regional Trial Court (RTC) found petitioner guilty beyond reasonable doubt and sentenced him to imprisonment and to pay the unpaid obligation plus interest. The Court of Appeals (CA) affirmed the RTC's decision. Petitioner appealed to the Supreme Court. The Petition: Petitioner assailed his conviction, arguing that the information was defective, he could not be held liable under Section 28 (h) of RA 8282, the prosecution failed to establish the employees' status, and his liability was extinguished by a compromise agreement.
Issue(s)
Whether the Court of Appeals correctly upheld the petitioner's conviction for violation of Section 22 (a), in relation to Section 28 (h) and (f), of RA 8282. Whether the Information was defective and if the defect was waived by the petitioner. Whether the petitioner, as President and Chairman of the Board, can be held liable for the non-remittance of SSS contributions. Whether the prosecution sufficiently established that the complainants were employees of FENICS. Whether petitioner's criminal liability was extinguished by a compromise agreement.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals, upholding the conviction of petitioner Jorge B. Navarra for violation of Section 22 (a), in relation to Section 28 (h) and (f), of RA 8282. Petitioner was sentenced to suffer imprisonment for the indeterminate period of four (4) years and two (2) months of prision correccional, as minimum, to twenty (20) years of reclusion temporal, as maximum, and ordered to pay the SSS the unpaid obligation of P9,577,656.24 plus three percent (3%) monthly interest.
Ratio Decidendi
On the overall conviction: The Court found that the prosecution, through documentary evidence, established beyond reasonable doubt that FENICS failed to remit SSS contributions from July 1997 to June 2000, despite withholding such amounts. The prompt remittance of SSS contributions is mandatory under Section 22 (a) of RA 8282, and failure to do so subjects the employer to criminal prosecution. On the alleged defect in the Information: The Court ruled that petitioner waived any defect in the Information by failing to raise the issue prior to entering his plea. Objections as to matters of form or substance in the Information cannot be made for the first time on appeal. Petitioner's attempt to raise this issue only after conviction and during appeal was deemed a waiver. On the petitioner's liability as a corporate officer: The Court affirmed that Section 28 (f) of RA 8282 explicitly provides that if the penalized act is committed by a corporation, its managing head, directors, or partners shall be liable. As President and Chairman of the Board, petitioner falls under this category. The Court reiterated that the failure to remit SSS contributions is considered mala prohibita, meaning the defenses of good faith and lack of criminal intent are immaterial. On the establishment of employee status: The Court noted that the prosecution presented documentary evidence which clearly showed that the private complainants were employees of FENICS. The factual findings of the RTC, affirmed by the CA, are entitled to great weight and respect when supported by evidence on record. On the alleged extinguishment of liability by compromise: The Court found no compromise agreement that could extinguish petitioner's criminal liability. The SSS did not assent to the proposed installment payments, and even if a compromise were assumed, it could not extinguish criminal liability.
Main Doctrine
Corporate officers, including the President and Chairman of the Board, are liable for the failure to remit SSS contributions withheld from employees, as such offenses are considered mala prohibita and the defenses of good faith or lack of criminal intent are immaterial. Furthermore, objections to the form or substance of an Information must be raised before entering a plea, otherwise, they are deemed waived.