Case Digest (G.R. No. 151458)
Facts:
In Emilio J. Aguinaldo IV v. People of the Philippines (G.R. No. 226615, January 13, 2021), petitioner Emilio J. Aguinaldo IV was convicted by the Regional Trial Court of Makati City, Branch 147, on June 18, 2013 for Estafa under Article 315(2)(a) of the Revised Penal Code for defrauding a private complainant of ₱2,050,000.00. The trial court imposed an indeterminate sentence of four (4) years and two (2) months of *prisión correccional* as minimum, to twenty (20) years of *reclusion temporal* as maximum. The Court of Appeals, in its Amended Decision dated August 25, 2016 (CA-G.R. CR. No. 36063), affirmed the conviction but deleted the award of actual damages and interest upon confirmation of the petitioner’s payment of ₱2,050,000.00. The Supreme Court, in a Resolution of October 10, 2018, affirmed the CA ruling. Petitioner’s first motion for reconsideration was denied in a Resolution of January 14, 2019, which directed immediate entry of judgment. Thereafter, Aguinaldo filed anCase Digest (G.R. No. 151458)
Facts:
- Prior Proceedings
- The Regional Trial Court (RTC) of Makati City, Branch 147, in Criminal Case No. 07-1545, found petitioner Emilio J. Aguinaldo IV guilty beyond reasonable doubt of Estafa under Article 315(2)(a) of the Revised Penal Code (RPC).
- The RTC sentenced him to an indeterminate penalty of four (4) years and two (2) months of prison correccional, as minimum, to twenty (20) years of reclusion temporal, as maximum, and ordered actual damages and interest.
- Court of Appeals Decision
- On August 25, 2016, the Court of Appeals (CA) in CA-G.R. CR No. 36063 rendered an Amended Decision, affirming the conviction and indeterminate penalty, but deleted the award of actual damages and interest due to petitioner’s payment of Php 2,050,000.00, as acknowledged by the private complainant.
- The CA’s Amended Decision was affirmed by this Court in a Resolution dated October 10, 2018.
- Post-Judgment Motions
- Petitioner’s motion for reconsideration was denied in a Resolution dated January 14, 2019, which also directed the immediate issuance of the Entry of Judgment.
- Despite the bar on further pleadings, petitioner filed on March 20, 2019 an Omnibus Motion for Leave to File a Second Motion for Reconsideration and to Refer the Case En Banc, and on March 9, 2020 an Urgent Motion for Recomputation of Penalty under RA 10951.
- Immutability and Supplementary Proceedings
- In a July 27, 2020 Resolution, the Court required submission of petitioner’s prison record, to which counsel replied that petitioner was on bail pending appeal.
- Entry of Judgment issued January 14, 2019 became final and executory, invoking the doctrine of immutability of judgment.
Issues:
- Whether the Omnibus Motion for Leave to File a Second Motion for Reconsideration and to Refer the Case En Banc may warrant reopening the judgment under the doctrine of immutability.
- Whether Republic Act No. 10951, which readjusted penalty thresholds, applies retroactively to petitioner’s final conviction to recompute his indeterminate penalty.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)