Aguinaldo IV vs. People

A final judgment of conviction may be modified to reduce an excessive penalty by applying a favorable retroactive law (Republic Act No. 10951) that lowers the prescribed range, and such reduction to a probationable penalty entitles the accused to apply for probation under Republic Act No. 10707 even after the original judgment became final.

Emilio J. Aguinaldo IV was charged with and convicted of Estafa for defrauding a private complainant of P2,050,000.00. The Regional Trial Court sentenced him to an indeterminate penalty of imprisonment, which the Court of Appeals affirmed. The Supreme Court initially affirmed the conviction on October 10, 2018, and denied reconsideration with finality on January 14, 2019, rendering the judgment immutable. Thereafter, Republic Act No. 10951 took effect in 2017, adjusting the values upon which penalties in the Revised Penal Code are based and effectively lowering the penalty range for the amount defrauded in this case.

• The Conviction: Petitioner was found guilty beyond reasonable doubt of Estafa under Article 315(2)(a) of the Revised Penal Code for defrauding the private complainant of P2,050,000.00. The Regional Trial Court of Makati City, Branch 147, sentenced him to suffer the indeterminate penalty of four (4) years and two (2) months of prision correccional, as minimum, to twenty (20) years of reclusion temporal, as maximum. The Court of Appeals affirmed the conviction in its Amended Decision dated August 25, 2016, but deleted the awards of actual damages and interest due to petitioner's full payment of the judgment award, which the private complainant acknowledged.
• Finality of Judgment: The Supreme Court affirmed the Court of Appeals' decision in a Resolution dated October 10, 2018. Petitioner filed a Motion for Reconsideration, which the Court denied with finality in a Resolution dated January 14, 2019, directing immediate entry of judgment. Entry of Judgment was issued on the same date, rendering the conviction final and executory.
• Subsequent Motions: Despite the finality, petitioner filed an Omnibus Motion dated March 20, 2019, seeking leave to file a second motion for reconsideration, referral to the Court En Banc, and second reconsideration, insisting on his innocence and praying for acquittal. He subsequently filed an Urgent Motion for Recomputation of Penalty dated March 9, 2020, praying that his sentence be readjusted in accordance with Republic Act No. 10951, which adjusted the value of property and damages on which penalties are based.
• Custodial Status: When required by the Court to submit prison records, petitioner manifested that he was on bail pending appeal and not confined in any prison.

• Innocence and Acquittal: Petitioner maintained that he was innocent of the crime charged and insisted on grounds previously raised, praying for acquittal from the final judgment of conviction.
• Retroactive Application of RA 10951: Petitioner argued that Republic Act No. 10951, enacted in 2017, should be applied retroactively to his case as it is favorable to the accused, reducing the penalty for Estafa involving the amount of P2,050,000.00 from the range under the old Article 315 to prision correccional in its minimum and medium periods.
• Eligibility for Probation: By implication, petitioner sought to render his sentence probationable, as the original sentence exceeded the probationable limit of six years imprisonment.

• Immutability of Judgment: The People contended that the judgment having become final and executory on January 14, 2019, the doctrine of immutability of judgment bars any further modification, correction, or reconsideration of the conviction or the penalty imposed.
• Lack of Compelling Circumstances: The People argued that no special or compelling circumstances existed to warrant an exception to the doctrine of immutability of judgment, and that the motion for second reconsideration was merely frivolous and dilatory.

• Immutability of Judgment: Whether the Court should entertain a second motion for reconsideration and referral to the En Banc after the Entry of Judgment has rendered the conviction final and executory.
• Retroactive Application of RA 10951: Whether Republic Act No. 10951, which reduces the penalties for Estafa based on the amount defrauded, may be retroactively applied to modify a final sentence.
• Correction of Excessive Penalty: Whether the Court retains the power to correct a sentence imposing a penalty in excess of the statutory maximum notwithstanding the finality of the judgment.
• Probation: Whether the reduction of penalty pursuant to Republic Act No. 10951 entitles the petitioner to apply for probation under Republic Act No. 10707.

• Immutability of Judgment: The Omnibus Motion was denied for lack of merit. The grounds raised were mere reiterations of arguments previously evaluated and passed upon, and no cogent reason existed to warrant application of the exceptions to the doctrine of immutability of judgment (matters of life, liberty, honor, or property; special or compelling circumstances; merits of the case; lack of fault or negligence; absence of frivolous or dilatory purpose; and lack of unjust prejudice to the other party).
• Retroactive Application of RA 10951 and Correction of Penalty: The Urgent Motion for Recomputation was granted. Notwithstanding the finality of criminal convictions, courts retain the power to correct a penalty found to be outside the range prescribed by law; a sentence imposing a penalty in excess of the statutory maximum is void for want of jurisdiction as to the excess. Republic Act No. 10951 expressly provides for retroactive effect if favorable to the accused, and the defrauded amount of P2,050,000.00 falls within the P1,200,000 to P2,400,000.00 bracket under Section 85 thereof, warranting prision correccional in its minimum and medium periods.
• Recomputed Penalty: Applying the Indeterminate Sentence Law and considering the absence of mitigating or aggravating circumstances, the proper penalty is four (4) months and twenty (20) days of arresto mayor, as minimum, to two (2) years, eleven (11) months, and ten (10) days of prision correccional, as maximum.
• Probation: The reduction of the penalty to a probationable range entitles petitioner to apply for probation pursuant to Section 1 of Republic Act No. 10707, which allows an accused convicted of a non-probationable penalty to apply for probation when the appellate court modifies the judgment to impose a probationable penalty, provided the application is filed before the modified decision becomes final.

• Doctrine of Immutability of Judgment — A decision that has acquired finality becomes immutable and unalterable and may no longer be modified in any respect, even to correct erroneous conclusions of fact or law. Its purposes are to avoid delay in the administration of justice and to terminate judicial controversies. Exceptions apply where: (a) matters of life, liberty, honor, or property are involved; (b) special or compelling circumstances exist; (c) the merits of the case warrant it; (d) the cause is not entirely attributable to the fault or negligence of the party favored; (e) the review sought is not frivolous and dilatory; and (f) the other party will not be unjustly prejudiced.
• Retroactive Effect of Favorable Penal Laws — Penal laws favorable to the accused have retroactive effect pursuant to Article 100 of the Revised Penal Code and Republic Act No. 10951.
• Correction of Void Sentence — Notwithstanding the finality of a criminal conviction, courts retain the power to correct the penalty imposed if found to be outside the range prescribed by law. A sentence imposing a penalty in excess of the statutory maximum is void for want of jurisdiction as to the excess.
• Probation under RA 10707 — An accused convicted of a non-probationable penalty who obtains a modification of the penalty to a probationable penalty on appeal may apply for probation based on the modified decision before such decision becomes final, filing the application in the trial court where the original judgment was rendered.

• "Time and again, the Court has repeatedly held that 'a decision that has acquired finality becomes immutable and unalterable, and may no longer be modified in any respect, even if the modification is meant to correct erroneous conclusions of fact and law, and whether it be made by the court that rendered it or by the Highest Court of the land. This principle, known as the doctrine of immutability of judgment, has a two-fold purpose, namely: (a) to avoid delay in the administration of justice and thus, procedurally, to make orderly the discharge of judicial business; and (b) to put an end to judicial controversies, at the risk of occasional errors, which is precisely why courts exist.'" — Articulates the rationale and scope of the doctrine of immutability of judgment.
• "However, this doctrine 'is not a hard and fast rule as the Court has the power and prerogative to relax the same in order to serve the demands of substantial justice considering: (a) matters of life, liberty, honor, or property; (b) the existence of special or compelling circumstances; (c) the merits of the case; (d) a cause not entirely attributable to the fault or negligence of the party favored by the suspension of the rules; (e) the lack of any showing that the review sought is merely frivolous and dilatory; and (f) that the other party will not be unjustly prejudiced thereby.'" — Enumerates the exceptions to the doctrine of immutability of judgment.
• "In Bigler v. People, the Court ruled that notwithstanding the finality of a criminal conviction, it still has the power to correct the penalty imposed against an accused-convict, if it finds the same to be outside the range prescribed by law. In this regard, the Court further elucidated that 'a sentence which imposes upon the defendant in a criminal prosecution a penalty in excess of the maximum which the court is authorized by law to impose for the offense for which the defendant was convicted, is void for want or excess of jurisdiction as to the excess.'" — Establishes the authority to correct excessive penalties despite finality of judgment.

• Uy v. Del Castillo, 814 Phil. 61 (2017) — Controlling precedent on the doctrine of immutability of judgment and its exceptions.
• Bigler v. People, 782 Phil. 158 (2016) — Controlling precedent on the power of courts to correct excessive penalties even after finality of judgment; established that sentences exceeding statutory maximum are void as to the excess.
• People v. Manlao, G.R. No. 234023, September 3, 2018 — Followed for the proposition that Republic Act No. 10951 has retroactive effect if favorable to the accused.
• Rivac v. People, 824 Phil. 156 (2018) — Followed for the retroactive application of Republic Act No. 10951.
• Hernan v. Sandiganbayan, 822 Phil. 148 (2017) — Followed for the rule under Republic Act No. 10707 allowing application for probation when a non-probationable penalty is modified to a probationable penalty on appeal.

• Article 315(2)(a), Revised Penal Code (as amended by Section 85 of Republic Act No. 10951) — Defines and penalizes Estafa with unfaithfulness or abuse of confidence; as amended, the penalty is prision correccional in its minimum and medium periods if the amount of fraud is over One million two hundred thousand pesos (P1,200,000) but does not exceed Two million four hundred thousand pesos (P2,400,000).
• Republic Act No. 10951 (2017) — "An Act Adjusting the Amount or the Value of Property and Damage on Which Penalty is Based, and the Fines Imposed Under the Revised Penal Code"; Section 85 amended Article 315 of the RPC, and Article 100 thereof provides for retroactive application if favorable to the accused.
• Republic Act No. 10707 (2015) — "An Act Amending Presidential Decree No. 968 (Probation Law of 1976)"; Section 1 allows application for probation when a judgment imposing a non-probationable penalty is modified through the imposition of a probationable penalty.
• Presidential Decree No. 968 (Probation Law of 1976) — As amended by Republic Act No. 10707.
• Article 100, Revised Penal Code — General rule on retroactivity of penal laws.

Caguioa, Delos Santos, Hernando, and Rosario, JJ.