Case Summary (G.R. No. 224943)
Applicable Law
The legal framework governing this case includes Republic Act No. 8282, also known as the Social Security Law, which was amended to strengthen the Social Security System (SSS) in the Philippines.
Background of the Case
The case originated from an Information filed on January 18, 2001, which charged Navarra with violating Section 22 (a), in relation to Section 28 (h) and (f) of RA 8282, concerning the non-remittance of SSS contributions. The specific allegations were that from July 1997 to June 2000, Navarra and other board members at FENICS failed to remit both the withheld employee contributions and the employer’s counterpart contributions, accumulating to a total unpaid obligation of approximately P10 million.
Proceedings at the Regional Trial Court
The Regional Trial Court (RTC) of Muntinlupa City found Navarro guilty beyond reasonable doubt in its March 13, 2013 ruling, leading to a significant sentence of four years and two months to twenty years of imprisonment, along with a financial obligation to pay the SSS over P9 million plus accruing interest. The RTC dismissed the defense arguments regarding the company's operational status and the custody of contributions, emphasizing the implications of Navarra's letters for settlements as acknowledgments of liability.
Court of Appeals Ruling
Navarra subsequently appealed the RTC's decision to the Court of Appeals (CA), which upheld the conviction on October 29, 2015. The CA determined that objections regarding the Information's validity were waived by Navarra’s failure to raise them prior to his plea. It reinforced that due to FENICS's corporate status, the personal liability of officers like Navarra is applicable given their failure to remit contributions.
Supreme Court's Resolution
Upon further review, the Supreme Court dismissed Navarra's petition, affirming the CA's decision. The Court ruled that his failure to object to the Information prior to arraignment amounted to a waiver of that argument. The Court's analysis confirmed that the prosecution had proved beyond reasonable doubt that during the relev
...continue readingCase Syllabus (G.R. No. 224943)
Case Background
- This case involves a petition for review on certiorari (G.R. No. 224943) filed by Jorge B. Navarra against the People of the Philippines.
- The petition challenges the Decision dated October 29, 2015, and the Resolution dated May 19, 2016, from the Court of Appeals (CA) in CA-G.R. CR No. 35855.
- The CA's decisions affirmed the ruling of the Regional Trial Court (RTC) of Muntinlupa City, Branch 206, dated March 13, 2013, which found Navarra guilty of violating specific provisions of Republic Act No. 8282.
Facts of the Case
- An Information dated January 18, 2001, charged Navarra with a violation of Section 22 (a), in relation to Sections 28 (h) and (f) of Republic Act No. 8282, during the period from July 1997 to June 2000.
- The charge stemmed from his failure, as a member of the board of directors of Far East Network of Integrated Circuits Subcontractors (FENICS) Corporation, to remit SSS contributions deducted from employees' salaries.
- FENICS failed to remit a total of P10,077,656.24 to the Social Security System (SSS) despite demands.
- Other co-accused were dismissed from the case as they were no longer serving on the board during the alleged period of criminal activity.
- Navarra pleaded "not guilty" to the charge.
- Evidence presented included complaints from FENICS employees regarding non-remittance and a subsequent investi