G.R. No. 226335 - People vs. Celorio

The case involves a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure, filed by the People of the Philippines and the Social Security System (SSS) against respondent Lilame V. Celorio.
The petition seeks to reverse and set aside the decisions and resolutions rendered by the Court of Appeals (CA) and the Regional Trial Court (RTC) of Quezon City, Branch 85 in criminal case proceedings.

Celorio, an SSS member, filed a claim for disability benefits for Pulmonary Tuberculosis on May 26, 2004.
In a routine check of settled disability benefit claims, it was discovered that the supporting documents for Celorio’s claim were suspected to be spurious.
An investigation by the SSS Fraud Investigation Department confirmed the documents were fraudulent, prompting the SSS to demand the return of benefits amounting to approximately P93,948.80.
After Celorio did not comply with the demand, the SSS instituted a criminal complaint before the Office of the City Prosecutor of Quezon City in connection with the alleged fraud.

On June 4, 2008, Celorio was charged with violating Section 28 (a) and (b) of Republic Act (R.A.) No. 1161, as amended by R.A. No. 8282, for making false statements in her disability claim, knowing that the supporting documents (including a medical certificate, chest X-ray, and radiologic report) were spurious.
On December 11, 2008, Celorio was arraigned and pleaded not guilty.
The RTC, after trial, rendered a Decision on April 23, 2013 (later amended), finding Celorio guilty beyond reasonable doubt.
The RTC imposed:

For violation of Section 28(a): an indeterminate penalty of imprisonment ranging from 1 year and 1 day to 4 years, 9 months and 11 days, and a fine of P5,000.
For violation of Section 28(b): a penalty of 1 year of imprisonment and a fine of P5,000.

The RTC further ordered that Celorio’s civil liability of P93,948.80 be offset against her SSS membership contributions of P122,270.60, resulting in a refund of P28,321.80 to her.

Celorio filed an application for probation on April 25, 2013, leading the SSS to file an urgent motion for reconsideration on April 26, 2013, contending that:

The RTC improperly imposed a penalty lower than the minimum prescribed by the amended Section 28(b) of R.A. No. 1161 (which mandates at least 6 years and 1 day of imprisonment).
The offsetting of her civil liability against her contributions was contrary to applicable law.

Denied the SSS’s motion for reconsideration on October 24, 2013, holding that the decision had attained finality upon the filing of the probation application.
Granted Celorio’s application for probation via a Resolution on December 19, 2013.

Petitioners later filed a Petition for Certiorari under Rule 65 before the CA, challenging:

The RTC’s decision imposing the improper penalty and its determination to offset the civil liability.
The CA’s dismissal of the petition on the ground that Rule 65 was an improper remedy and that the errors committed were errors of judgment rather than jurisdictional errors.

Whether a petition for certiorari under Rule 65 is the proper remedy to assail the RTC’s Amended Decision and Resolutions, particularly when challenging an allegedly improper imposition of penalty and erroneous offsetting of civil liabilities.
Whether the RTC’s actions—specifically, imposing a sentence based on a repealed law and finalizing its decision upon the defendant’s filing for probation—amount to grave abuse of discretion tantamount to lack or excess of jurisdiction.

Whether the trial court erred in sentencing Celorio to a penalty of one (1) year imprisonment for violation of Section 28(b) of R.A. No. 1161, instead of imposing the minimum penalty of six (6) years and one (1) day as mandated by the amended law (R.A. No. 8282).
Whether imposing a sentence based on an outdated penalty provision constitutes a legally baseless act.

Whether it was proper for the RTC to order the offsetting of Celorio’s civil liability against her SSS membership contributions.
Whether such offsetting violates the principles of compensation under the Civil Code (specifically Article 1288) and the governing provisions of the Social Security Law.

Whether Celorio’s application for probation was proper given that the correct imposition of the minimum penalty under R.A. No. 8282 would render her disqualified from availing of probation benefits under Presidential Decree No. 968.

Whether reviewing the sentence through a petition for certiorari (which challenges errors of jurisdiction) rather than through an ordinary appeal conflicts with the rule on double jeopardy, given that an appeal seeking an increased penalty may put the accused in jeopardy again.