Case Digest (G.R. No. 226615)
Facts:
The case involves Emilio J. Aguinaldo IV as the petitioner and the People of the Philippines as the respondent. The events leading to this case began when Aguinaldo was found guilty of Estafa, a crime defined and penalized under Article 315 (2) (a) of the Revised Penal Code (RPC). The Court of Appeals (CA) issued an Amended Decision on August 25, 2016, affirming the Regional Trial Court's (RTC) ruling, which sentenced Aguinaldo to an indeterminate prison term ranging from four years and two months of prison correccional to twenty years of reclusion temporal. The CA also deleted the awards for actual damages and interest, acknowledging that Aguinaldo had already paid the private complainant the amount of P2,050,000.00. Aguinaldo filed a motion for reconsideration, which was denied on January 14, 2019, with a directive that no further pleadings or motions would be entertained, leading to the issuance of an Entry of Judgment. Despite this, Aguinaldo filed multiple motions, i...
Case Digest (G.R. No. 226615)
Facts:
Background of the Case
- Petitioner Emilio J. Aguinaldo IV was convicted of Estafa under Article 315 (2)(a) of the Revised Penal Code (RPC) for defrauding the private complainant of P2,050,000.00.
- The Court of Appeals (CA) affirmed the Regional Trial Court's (RTC) decision, sentencing petitioner to an indeterminate penalty of 4 years and 2 months of prision correccional (minimum) to 20 years of reclusion temporal (maximum).
- The CA deleted the awards of actual damages and interest after petitioner paid the judgment award of P2,050,000.00, which was acknowledged by the private complainant.
Post-Conviction Motions
- Petitioner filed a motion for reconsideration, which was denied with finality on January 14, 2019. The Court issued an Entry of Judgment, making the conviction final and executory.
- Despite this, petitioner filed two subsequent motions:
- Omnibus Motion (March 20, 2019): Requested leave to file a second motion for reconsideration, referral to the Court En Banc, and a second reconsideration, insisting on his innocence.
- Urgent Motion for Recomputation of Penalty (March 9, 2020): Sought a readjustment of his sentence under Republic Act No. (RA) 10951, which adjusted penalties based on the current value of money.
Prison Record and Bail Status
- The Court required petitioner’s prison record, but petitioner informed the Court that he was on bail pending appeal and not confined in any prison.
Issue:
- Whether the doctrine of immutability of judgment bars the Court from reconsidering petitioner’s conviction.
- Whether petitioner’s sentence should be recomputed under RA 10951, which retroactively adjusts penalties for Estafa.
- Whether petitioner is entitled to apply for probation under RA 10707 after the recomputation of his penalty.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Disposition
- The Court denied petitioner’s Omnibus Motion for lack of merit.
- The Court granted petitioner’s Urgent Motion for Recomputation of Penalty, lifting the Entry of Judgment and modifying his sentence to an indeterminate penalty of 4 months and 20 days of arresto mayor (minimum) to 2 years, 11 months, and 10 days of prision correccional (maximum).
- Petitioner is entitled to apply for probation under RA 10707.