Case Digest (G.R. No. 224943)
Facts:
Jorge B. Navarra v. People of the Philippines, G.R. No. 224943, March 20, 2017, Supreme Court First Division, Perlas‑Bernabe, J., writing for the Court. Petitioner Jorge B. Navarra (petitioner) was prosecuted by the People of the Philippines for violation of Section 22(a), in relation to Sections 28(h) and (f), of Republic Act No. 8282 (RA 8282, the Social Security Law) for the alleged nonremittance of Social Security System (SSS) contributions by his employer, Far East Network of Integrated Circuits Subcontractors (FENICS) Corporation.An Information dated January 18, 2001 charged petitioner with willfully failing to remit employee SSS/Medicare/EC contributions and employer counterparts withheld from July 1997 to June 2000 despite demands. Eleven former employees filed complaints with the SSS Alabang Branch; Account Officer Felicula B. Argamosa’s investigation established FENICS’s unpaid obligations at P10,077,656.24 (exclusive of the 3% monthly penalty). The SSS filed an Affidavit‑Complaint; petitioner submitted settlement letters (October 25, 2000 and April 25, 2003) and two postdated checks (one encashed, one dishonored), but did not complete proposed installment payments.
At the Regional Trial Court (RTC), petitioner pleaded not guilty. The RTC (Branch 206, Muntinlupa City) found him guilty in a Decision dated March 13, 2013, sentenced him to an indeterminate term of imprisonment (four years and two months to twenty years) and ordered payment of P9,577,656.24 plus 3% monthly interest, discrediting his claim that FENICS had already shut down and treating his settlement attempt as an implied admission.
Petitioner appealed to the Court of Appeals (CA) in CA‑G.R. CR No. 35855. The CA, in a Decision dated October 29, 2015, affirmed the RTC in toto, ruling (inter alia) that petitioner waived any defect in the Information by not objecting prior to plea; that corporate officers may be held liable under RA 8282 (particularly where the corporation was dissolved); that documentary evidence established the complainants’ employment; and that no valid compromise extinguished criminal liability. The CA denied reconsideration in a Resolution dated May 19, 2016.
Petitioner filed this pe...(Pro-only)
Issues:
- Did the Court of Appeals correctly uphold petitioner’s conviction for violation of Section 22(a), in relation to Sections 28(h) and (f), of RA ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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