Title
Aguinaldo IV vs. People
Case
G.R. No. 226615
Decision Date
Jan 13, 2021
Petitioner convicted of Estafa sought reconsideration and recomputation of penalty under RA 10951. Court denied reconsideration but granted recomputation, reducing sentence to probationable range, allowing probation eligibility.
Font Size:

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:
    1. 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.
    2. 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:

  1. Whether the doctrine of immutability of judgment bars the Court from reconsidering petitioner’s conviction.
  2. Whether petitioner’s sentence should be recomputed under RA 10951, which retroactively adjusts penalties for Estafa.
  3. 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.


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.