G.R. No. L-57298 - Myc-Agro-Industrial Corp. vs. Vda. de Caldo

The People of the Philippines (Petitioner) filed a petition for certiorari with an urgent prayer for the issuance of a temporary restraining order (TRO) and/or writ of preliminary injunction against Hon. Amelia A. Fabros-Corpuz, Acting Presiding Judge of RTC, Muntinlupa City, Branch 256 (Public Respondent), and Anthony Archangel y Sy (Private Respondent).
The petition challenged the RTC Resolution dated March 14, 2019, which modified the penalties imposed on respondent Sy for three counts of Estafa and ordered his immediate release from detention pursuant to Republic Act No. 10951.

On February 8, 2001, respondent Sy was charged in nine separate criminal informations for Estafa under Article 315, paragraph 2(d) of the Revised Penal Code (RPC) for issuing nine worthless bank checks.
Five of the cases were dismissed, leaving four criminal cases docketed as Criminal Case Nos. U-11223, U-11226, U-11227, and U-11228.
Allegations in Criminal Case No. U-11223 involved respondent Sy purchasing construction materials and paying with two checks amounting to PHP 41,800.00 and PHP 41,500.00, which were dishonored due to closed accounts, causing damage to the complainant.

On September 3, 2007, RTC, Branch 48, Urdaneta City found respondent Sy guilty beyond reasonable doubt for three counts of Estafa.
Penalties imposed were prison mayor sentences ranging from minimum of 4 years, 2 months, and 1 day to maximum of 8 years, plus payment of damages.
Respondent Sy was acquitted in Criminal Case No. U-11228.

On December 22, 2018, respondent Sy filed a Petition to Adjust and Fix Penalty and Motion to Release before the RTC of Muntinlupa City invoking the effect of RA 10951 which adjusted penalties under RPC.
He argued that his adjusted penalty based on the new law should be reduced to arresto mayor up to prision correccional, and that he had already served more than 21 years with good conduct time.
The RTC, through Public Respondent, issued a Resolution on March 14, 2019, granting the petition, modifying the penalty, and ordering the immediate release of Sy from prison.

The People, through the Office of the Solicitor General (OSG), filed the present Petition for Certiorari before the Supreme Court under Rule 65 of the Rules of Court.
The OSG argued that the Public Respondent misapplied RA 10951 by applying a penalty not authorized for Estafa through issuance of worthless checks under Article 315(2)(d) of the RPC which actually mandates a higher penalty.
They contended that the original penalties should be maintained and the immediate release was unwarranted as respondent Sy had not yet served his full term based on the correct penalty.

The Supreme Court issued a TRO enjoining enforcement of the RTC Resolution and directed respondents to file comments.
After procedural delays and extensions, the case records were elevated and memoranda were filed.

Whether the public respondent committed grave abuse of discretion amounting to lack or in excess of jurisdiction in adjusting respondent Sy’s prison sentence under RA 10951 and ordering his immediate release.