G.R. No. 159418-19 - De Joya vs. Jail Warden of Batangas City

Case Summary (G.R. No. 159418-19)

Facts of the Case

Norma de Joya was separately charged before the Municipal Trial Court in Batangas City for violations of Batas Pambansa Blg. 22, which penalizes the issuance of worthless checks. Two specific cases involved her issuing to two complainants, Flor Catapang de Tenorio and Resurreccion T. Castillo, postdated checks amounting to P150,000 and P225,000, respectively, both dishonored due to “account closed.” She was arraigned and pleaded not guilty but jumped bail before the conclusion of the trials. Consequently, no defense evidence was presented on her behalf.

Trial Court Decisions and Sentence

The court rendered judgment in absentia:

In Criminal Case No. 25484, petitioner was convicted and sentenced to one year imprisonment and indemnification of P150,000 (December 14, 1995).
In Criminal Case No. 25773, petitioner was similarly convicted and sentenced to one year imprisonment and payment of P225,000 damages (March 21, 1997).

Petitioner did not appeal these decisions, which then became final and executory.

Arrest, Detention, and Motion for Release

After remaining at large for five years, Norma de Joya was arrested on December 3, 2002, while applying for an NBI clearance and detained at Batangas City Jail. In 2003, she filed a motion requesting the retroactive application of Supreme Court Administrative Circular No. 12-2000—issued in 2000—which prescribed guidelines on the imposition of penalties for B.P. Blg. 22 violations, favoring fines over imprisonment. The Municipal Trial Court denied the motion on three bases:
(a) The court decisions were final and could no longer be amended;
(b) The Circular should apply prospectively, not retroactively;
(c) The Circular did not amend the substantive law but served only as a guideline on penalty imposition.

Arguments Presented

Petitioner contended that Administrative Circular No. 12-2000 effectively removed imprisonment as a penalty for B.P. Blg. 22 violations and should be applied retroactively according to Article 22 of the Revised Penal Code, referencing prior Supreme Court rulings on the retroactive application of laws mitigating penalties. She claimed her continued detention was unlawful.

Opposing her petition, the Office of the Solicitor General argued:

The convictions were final and not subject to modification;
The administrative circulars did not delete imprisonment as a penalty but merely recommended a rule of preference to impose fines based on circumstances;
Reliance on Article 22 of the Revised Penal Code was misplaced since the circular was not a law but an administrative guideline.

Legal Principles on Habeas Corpus and Finality of Judgment

Under Section 4, Rule 102 of the Rules of Court, a writ of habeas corpus is not available to persons detained pursuant to a process issued by a court of record with jurisdiction, even if there are informalities or defects. Since the petitioner was lawfully detained under final judgments of conviction, her petition for habeas corpus was properly denied.

Nature and Effect of Supreme Court Administrative Circular No. 12-2000

The circular does not amend or repeal B.P. Blg. 22 but provides a rule of preference for imposing penalties. It recommends the imposition of fines alone when circumstances such as the good faith or clear mistake of the offender warrant leniency but does not preclude imprisonment. The decision to impose imprisonment remains within the sound discretion of the courts, considering the totality of circumstances. Thus, the circular functions as a guideline to promote uniformity and flexibility but does not legally alter the substantive penalties prescribed by law.

Penal Law on Worthless Checks Under B.P. Blg. 22

Section 1 of B.P. Blg. 22 establishes alternative penalties for issuing checks without sufficient funds: imprisonment from 30 days to 1 year, a fine ranging from the amount of the check to double, or both, all at the court's discretion. The law serves a public purpose by protecting commercial transactions and the banking system from abuse. It places the offense as one against public order rather than solely property rights.

Judicial Discretion and Principles in Imposing Penalties

Philippine penal law balances retributive and reformative purposes. Judges must consider the convict’s moral culpability, circumstances of the

Case Syllabus (G.R. No. 159418-19)

Facts and Antecedents of the Case

Norma de Joya was separately charged with violations of Batas Pambansa (B.P.) Blg. 22 before the Municipal Trial Court in Cities in Batangas.
In Criminal Case No. 25484, she was accused of issuing a postdated check for ₱150,000.00 from Solid Bank, which was dishonored due to "account closed," a cause considered graver than insufficient funds.
In Criminal Case No. 25773, she was accused of issuing another postdated check for ₱225,000.00 from Security Bank and Trust Company, also dishonored on the ground of "account closed."
Despite notices of dishonor and demands for payment, petitioner failed and refused to settle the obligations in both cases.
Upon arraignment, the petitioner pleaded not guilty but subsequently jumped bail without offering any evidence in her defense.
On December 14, 1995, and March 21, 1997, the trial court found her guilty in absentia for both offenses and sentenced her to one year imprisonment and to indemnify the offended parties corresponding amounts.
Petitioner remained at large for about five years until her arrest on December 3, 2002, upon applying for an NBI clearance.
An urgent motion seeking retroactive application of Supreme Court Administrative Circular No. 12-2000, which prefers the imposition of fines over imprisonment for B.P. 22 violations, was filed but denied by the trial court.
The trial court denied the motion on grounds of finality of judgment, prospectivity of circular, and the circular’s non-amendment of substantive law.

Issues Presented

Whether the writ of habeas corpus should be issued to order petitioner’s release from detention.
Whether Supreme Court Administrative Circular No. 12-2000 deleting imprisonment as a penalty for B.P. Blg. 22 violations applies retroactively to petitioner’s final judgment.
Whether the penalty imposed by the trial court could be modified or altered after finality.
The legal effect and scope of SC Administrative Circulars No. 12-2000 and No. 13-2001 on penalties for violation of B.P. Blg. 22.

Petitioner's Arguments

Petitioner contends that her detention is illegal as SC Administrative Circular No. 12-2000 deleted imprisonment as a penalty and allows only fines.
She claims that the trial court is mandated to apply the circular retroactively by virtue of Article 22 of the Revised Penal Code, referencing United States v. Pacrose.
Requests issuance of writ of habeas corpus and release from Batangas City Jail based on the circular’s supposed retroactive effect.

Respondents’ and Office of the Solicitor General’s (OSG) Opposition

Contends that the judgments convicting petitioner have long attained finality and could no longer be modified.
Argues that Administrative Circular No. 12-2000 as modified by Administrative Cir