Case Summary (G.R. No. 117857)
Applicable Law
The case was decided on June 25, 2001, thus the 1987 Philippine Constitution was the applicable legal framework. The petitioner was convicted under BP Blg. 22, which penalizes the issuance of checks without sufficient funds or credit.
Prior Decision and Motion for Reconsideration
The Court of Appeals’ earlier decision, promulgated on February 2, 2001, removed the imprisonment penalty but required petitioner Wong to pay fines totaling twice the face value of the three checks and a civil indemnity of P18,025.00. Petitioner filed a motion for reconsideration, asserting that the civil indemnity amount was incorrect. He argued that the figure mistakenly included checks related to a separate case in which he had been acquitted.
Court’s Finding on Motion
The court found merit in the petitioner’s motion only insofar as the recomputation of the civil indemnity was concerned. It acknowledged that the original civil indemnity assessment erroneously included checks from a different, already acquitted case, constituting an inadvertent error.
Revised Penalties and Civil Indemnity
The Court amended the prior decision accordingly. Petitioner was ordered to pay fines corresponding to twice the face value of the three checks involved in the present criminal cases, specifically: P6,750.00 for CBU-12057, P12,820.00 for CBU-12058, and P11,000.00 for CBU-12055, with subsidiary imprisonment in case of insolvency. Importantly, the civil indemnity was reduced to P15,285.00, reflecting only the face value of the checks actually involved, with legal interest from the filing date of the charges. The court also upheld the order for petitioner to pay court costs.
Final Disposition
The petit
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Background and Procedural History
- The case originated from criminal charges against petitioner Luis S. Wong for violating the Bouncing Checks Law (Batas Pambansa Blg. 22).
- Wong was convicted and sentenced by the trial court, which imposed penalties including imprisonment, fines, and civil indemnity.
- The Court of Appeals rendered a decision on February 2, 2001, following policy guidelines in AC No. 12-2000.
- The Court of Appeals deleted the imprisonment penalty but ordered Wong to pay fines corresponding to twice the face value of each of three checks involved in three separate criminal cases: CBU-12057, CBU-12058, and CBU-12055.
- The Court also imposed a civil indemnity of P18,025.00 and costs to be paid by Wong.
- Wong, through counsel, filed a motion for reconsideration, challenging the amount of civil indemnity imposed.
Issues Presented
- Whether there was an error in the computation of civil indemnity imposed on petitioner Luis S. Wong.
- Whether the civil indemnity should be corrected by reducing the amount as per Wong’s motion for reconsideration.
Petitioner’s Argument in the Motion for Reconsideration
- Petitioner contended that the amount of civil indemnity was erroneously based on the addition of three checks partly because one of those checks was involved in a separate case where he was acquitted.
- The acquittal concerning those three checks had been acknowledged by the Court in a footnote in its previous decision.
- The alleged error stemmed from an inadvertent addition of checks not related to the present cases, thus inflating the civil indemnity improperly.
- Wong respectfully requested correction of this error and recomputation of the civil indemnity to reflect only those checks involved in the present cases.
Supreme Court’s Resolution and Ruling
- The Court found t