Case Summary (G.R. No. 233988)
Facts of the Case
Lilame V. Celorio, a member of the SSS, filed a claim for disability benefits on May 26, 2004, citing Pulmonary Tuberculosis as the basis for her request. An investigation revealed that the supporting documents submitted were fraudulent, leading the SSS to demand the return of the disbursed benefits totaling P93,948.80. When she failed to comply, the SSS filed a criminal complaint against her. The RTC found her guilty on April 23, 2013, sentencing her to an erroneous term of one year imprisonment and a fine of P5,000, despite the law mandating a minimum of six years and one day for the offenses charged.
Ruling of the Regional Trial Court
The RTC concluded, in its amended decision, that Celorio was guilty beyond reasonable doubt of violating Section 28(a) and (b) of the amended Social Security Law and imposed a light penalty inconsistent with statutory requirements. Importantly, the RTC ordered the offsetting of Celorio's civil liability against her SSS contributions, which evoked further legal debates.
Appeal and Decisions of the Court of Appeals
Petitioners sought relief through a Petition for Certiorari under Rule 65, arguing that the RTC committed grave abuse of discretion in both the penalty imposed and the incorrect offsetting of civil obligations. However, the Court of Appeals held that the proper remedy was an ordinary appeal, not certiorari, resulting in the dismissal of the petition.
Proceedings before the Supreme Court
The Supreme Court undertook a comprehensive review of the case, determining that the RTC had indeed committed grave abuse of discretion by imposing an illegal sentence based on outdated provisions of law. This legal misstep rendered Celorio's punishment invalid, which permitted the prosecution to challenge the decision despite the procedural bars often associated with applications for probation.
Legal Principles Addressed
The Court asserted the distinction between grave abuse of discretion, which allows for certiorari, and errors of judgment, which do not. It reiterated that a proper imposition of sentence is a core function of the trial
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Background of the Case
- The case involves a Petition for Review on Certiorari filed by the People of the Philippines and the Social Security System (SSS) against Lilame V. Celorio.
- The petition seeks to reverse the Decision dated April 7, 2016, and the Resolution dated August 9, 2016, from the Court of Appeals (CA), which denied the petitioners' Petition for Certiorari for being the wrong remedy.
- The underlying action began with an Amended Decision dated April 23, 2013, from the Regional Trial Court (RTC) of Quezon City, Branch 85, which granted Celorio's application for probation after finding her guilty of violations under the Social Security Law.
Facts of the Case
- Celorio is a member of the Social Security System (SSS) and filed a claim for disability benefits due to Pulmonary Tuberculosis on May 26, 2004.
- The SSS discovered that the supporting documents for her claim were fraudulent, leading to a demand for the return of benefits totaling P93,948.80, which Celorio ignored.
- Consequently, a criminal complaint was filed against her, leading to charges of making false statements in her disability claim under Section 28 of Republic Act No. 1161.
Ruling of the Regional Trial Court
- The RTC found Celorio guilty beyond reasonable doubt of violating Section 28(a) and (b) of R.A. No. 1161.
- The RTC imposed an indeterminate penalty of imprisonment ranging from one year and one day to four years, nine months, and eleven days, along with a fine of P5,000.
- The RTC also ordered the civil in