Case Summary (G.R. No. 96053)
Factual Background and Trial Court’s Decision
Emilio J. Aguinaldo IV was charged with defrauding a private complainant of ₱2,050,000.00. The Regional Trial Court of Makati City, Branch 147, found him guilty of Estafa and imposed an indeterminate sentence of four years and two months of prison correccional (minimum) to twenty years of reclusion temporal (maximum). Actual damages and interest were deleted by the Court of Appeals upon acknowledgment of payment by Aguinaldo.
Procedural History and Initial Supreme Court Resolution
On October 10, 2018, the Supreme Court affirmed the Court of Appeals’ Amended Decision of August 25, 2016. Aguinaldo’s motion for reconsideration was denied in a January 14, 2019 Resolution, with a directive that no further pleadings be entertained and entry of judgment issued immediately. Judgment became final and executory the same day.
Doctrine of Immutability of Judgment
The Court reaffirmed that a final and executory decision is immutable to ensure judicial finality and orderly administration of justice. Exceptions to immutability may apply to serve substantial justice—considering life, liberty, property, special circumstances, merits, absence of dilatory intent, and lack of prejudice to other parties—but must be compelling.
Analysis of the Omnibus Motion for Reconsideration
Petitioner’s Omnibus Motion (March 20, 2019), which reiterated grounds already adjudicated, failed to establish any exception to the doctrine of immutability. Consequently, the Court denied it for lack of merit.
Analysis of the Urgent Motion for Recomputation of Penalty
Petitioner’s Urgent Motion (March 9, 2020) sought sentence readjustment under Republic Act No. 10951 (RA 10951), which adjusted property values and penalties under the Revised Penal Code. RA 10951 expressly provides retroactive effect if favorable to the accused.
Application of RA 10951 and Penalty Modification
Under Article 315(2)(a) as amended by RA 10951, Estafa involving amounts over ₱1,200,000 but not exceeding ₱2,400,000 carries prision correccional in its minimum and medium periods. Applying this schedule, the Court reduced Aguinaldo’s sentence to an indeterminate term of four months and twenty days of arresto mayor (minimum) to two years, eleven months, and ten days of prision correccional (maximum). Relying on Bigler v. People, the Court exercised its power to correct an excessive penalty even after finality.
Probation Eligibility under RA 10707
The modified sentence is now probationable under RA 10707.
Case Syllabus (G.R. No. 96053)
Factual and Procedural Background
- Petitioner Emilio J. Aguinaldo IV was charged with estafa under Article 315(2)(a) of the Revised Penal Code for defrauding the private complainant of ₱2,050,000.00.
- The Regional Trial Court of Makati City, Branch 147, found him guilty and imposed an indeterminate sentence of four (4) years and two (2) months of prison correccional (minimum) to twenty (20) years of reclusion temporal (maximum).
- The Court of Appeals (CA), in CA-G.R. CR. No. 36063, affirmed the conviction but deleted awards of actual damages and interest upon petitioner’s payment of ₱2,050,000.00.
- Petitioner’s motion for reconsideration before the CA was denied in a Resolution dated January 14, 2019, with a directive that “no further pleadings or motions shall be entertained.” Entry of Judgment was issued the same date.
- Despite this, petitioner filed:
- An Omnibus Motion (incorporating a second motion for reconsideration, a referral to the Court en banc, and a second reconsideration) on March 20, 2019; and
- An Urgent Motion for Recomputation of Penalty on March 9, 2020.
Doctrine of Immutability of Judgment and Its Exceptions
- Once an Entry of Judgment becomes final and executory, the conviction attains immutability and cannot be modified, even to correct errors of fact or law.
- The doctrine’s purposes are to avoid delay, ensure orderly judicial business, and terminate controversies at the risk of occasional errors.
- Exceptions to the doctrine allow modification in the interest of substantial justice when:
- Life, liberty, honor, or property is at stake;
- Special or compelling circumstances exist;
- The merits warrant relief;
- The cause is not wholly the fault of the party seeking relief;
- The ap