De Joya vs. Jail Warden of Batangas City

Facts:

The petitioner, Norma de Joya, was charged in two separate informations in the Municipal Trial Court in Cities (Batangas City) for violations of Batas Pambansa Blg. 22 (dishonored checks): Criminal Case No. 25484 (check to Flor Catapang de Tenorio for P150,000, dated Sept. 28, 1994) and Criminal Case No. 25773 (check to Resurreccion T. Castillo for P225,000, dated Oct. 17, 1994). She pleaded not guilty in both cases, but while trial was ongoing she jumped bail and did not present any evidence in her defense.

The trial court promulgated judgment in absentia: on December 14, 1995 in Criminal Case No. 25484, finding her guilty and sentencing her to one year imprisonment and indemnity of P150,000; and on March 21, 1997 in Criminal Case No. 25773, sentencing her to one year imprisonment and damages of P225,000. No appeals were filed and the judgments became final and executory. The petitioner remained at large for about five years.

On November 21, 2000 the Court issued Supreme Court Administrative Circular No. 12-2000 (referencing this Court’s rulings in Vaca v. Court of Appeals and Lim v. People) advising trial courts on the selection of penalties under B.P. Blg. 22; this was later clarified by Administrative Circular No. 13-2001. Petitioner was arrested on December 3, 2002 while applying for an NBI clearance and detained at Batangas City Jail. On July 28, 2003 she filed an urgent motion in the municipal court asking application of SC Admin. Circular No. 12-2000 retroactively under Article 22 of the Revised Penal Code; the public prosecutor opposed. On August 15, 2003 the trial court denied the motion, ruling (a) the convictions were final and could not be amended; (b) the Circular should be applied prospectively only; and (c) the Circular did not amend B.P. Blg. 22 but merely recommended a uniform approach to penalty imposition.

Petitioner then filed the present petition for a writ of habeas corpus in the Supreme Court seeking release. The Office of the Solicitor General opposed, arguing...(Pro-only)

Issues:

• Is the petitioner entitled to the writ of habeas corpus despite being held under final judgments of conviction by the Municipal Trial Court?
• Does SC Administrative Circular No. 12-2000 (as modified by Administrative Circular No. 13-2001) operate retroactively to benefit the petitioner by removing or precluding imprisonment under B.P. Blg. 22, thus invoking Art...(Pro-only)

Ruling:

• (Pro-only)

Ratio:

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Doctrine:

• (Pro-only)