Case Digest (G.R. No. 226615)
Facts:
Petitioner Emilio J. Aguinaldo IV was convicted by the Regional Trial Court, Makati, Branch 147 for Estafa under Article 315(2)(a) of the Revised Penal Code for defrauding the private complainant of P2,050,000.00; the Court of Appeals affirmed in an Amended Decision dated August 25, 2016, and the Supreme Court affirmed in a Resolution dated October 10, 2018, with an Entry of Judgment issued January 14, 2019. Petitioner filed motions for reconsideration and an Urgent Motion for Recomputation of Penalty under RA 10951, which the Court resolved after petitioner informed it that he was on bail pending appeal.
Issues:
- Whether the Court should grant petitioner’s Omnibus Motion for leave to file a second motion for reconsideration and to refer the case to the Honorable Court en banc to overturn his conviction.
- Whether the Court should grant petitioner’s Urgent Motion for Recomputation of Penalty and modify his sentence pursuant to RA 10951.
Ruling:
The Court denied petitioner’s Omnibus Motion for reconsideration and referral en banc for lack of merit and affirmed petitioner’s conviction as final and executory. The Court granted the Urgent Motion for Recomputation of Penalty, lifted the Entry of Judgment dated January 14, 2019 solely to modify the penalty, and affirmed its prior resolutions with modification, reducing the sentence to an indeterminate term of four months and twenty days of arresto mayor as minimum to two years, eleven months, and ten days of prision correccional as maximum.
Ratio:
The Court applied the immutability of judgment doctrine, finding the first motion merely reiterated grounds already considered and thus did not meet exceptions permitting relaxation of finality. For the recomputation, the Court held that RA 10951 adjusted penalty thresholds and operates retroactively when favorable to the accused, and that under Bigler v. People the Court retains authority to correct penalties imposed in excess of statutory limits; applying the Indeterminate Sentence Law and noting absence of aggravating or mitigating circumstances, the Court recalculated the proper penalty range for the P2,050,000.00 fraud.
Doctrine:
- Immutability of judgment bars reconsideration of issues already finally adjudicated unless recognized exceptions for substantial justice apply.
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