Title
Supreme Court
Go vs. Dimagiba
Case
G.R. No. 151876
Decision Date
Jun 21, 2005
Respondent convicted under BP 22 for 13 dishonored checks; RTC improperly granted habeas corpus, imposing fine instead of imprisonment. SC nullified RTC's ruling, upholding finality of judgment and denying retroactive application of SC-AC No. 12-2000.

Case Digest (G.R. No. 170979)
Expanded Legal Reasoning Model

Facts:

  • Issuance and dishonor of checks
    • Respondent Fernando L. Dimagiba issued thirteen (13) checks to Susan Go that were dishonored by the drawee bank for “account closed.”
    • Separate complaints for BP 22 violations were filed with the Municipal Trial Court in Cities (MTCC), Baguio City (Branch 4).
  • MTCC conviction and civil liability
    • On July 16, 1999, MTCC Branch 4 rendered a joint Decision convicting Dimagiba of 13 counts of violation of BP 22, sentencing him to 3 months imprisonment per count and ordering indemnification of P1,295,000 plus legal interest, attorney’s fees of P15,000, and costs.
    • Dimagiba appealed to RTC Branch 4, which denied the appeal on May 23, 2000; a Certificate of Finality was issued on February 1, 2001.
  • Enforcement proceedings and motions for reconsideration
    • On February 14, 2001, MTCC Branch 4 issued an Order of Arrest and Writ of Execution for the civil liability.
    • Dimagiba filed (a) a Motion for Reconsideration (Feb. 27, 2001) seeking recall of the arrest order and modification of sentence, and (b) a Motion for Partial Quashal of the Writ of Execution (Feb. 28, 2001); both were denied on August 22, 2001.
  • Habeas corpus petition and RTC orders
    • Dimagiba filed a Petition for Writ of Habeas Corpus with RTC Branch 5, Baguio City, on October 9, 2001; hearing was held on October 10, 2001.
    • On October 10, 2001, RTC Branch 5 ordered his immediate release and imposed a fine of P100,000 in lieu of imprisonment; a more detailed Order followed on October 11, 2001.
  • Petition for review in the Supreme Court
    • Susan Go and the People of the Philippines filed a petition under Rule 45 to challenge the RTC’s October 10 and 11, 2001 Orders on pure questions of law.
    • The petition was submitted for decision after memoranda from both sides were filed.

Issues:

  • Jurisdiction
    • Whether RTC Branch 5 had jurisdiction to amend a final and conclusive MTCC judgment (July 16, 1999) and Sentence Mittimus (Sept. 28, 2001) by granting habeas corpus relief.
  • Proper remedy and merit of habeas corpus
    • Whether habeas corpus was the proper remedy or whether the accused should have appealed the MTCC’s denial of his motions for reconsideration.
    • Whether Dimagiba was entitled to the policy in Eduardo Vaca and Rosa Lim and Supreme Court Administrative Circular No. 12-2000.
  • Quantum of fine
    • Whether, even if entitled to the policy, the fine should be the minimum of P1,295,000 up to P2,590,000, rather than P100,000.
  • Procedural due process
    • Whether RTC Branch 5 committed grave abuse of discretion by hearing and deciding the habeas corpus petition without notice to or participation by the People of the Philippines through the City Prosecutor or Solicitor General.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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