G.R. No. 197582 , June 29, 2015
Julie S. Sumbilla, Petitioner, vs. Matrix Finance Corporation, Respondent.

FACTS

Petitioner Julie S. Sumbilla obtained a cash loan from respondent Matrix Finance Corporation. As partial payment, she issued six checks, each with a face value of ₱6,667.00. All checks were dishonored upon presentment for being drawn against a closed account. Petitioner was subsequently convicted of six counts of violation of Batas Pambansa Blg. 22 (BP 22) by the Metropolitan Trial Court (MeTC) of Makati City. The MeTC Decision dated January 14, 2009, imposed a penalty of a fine of ₱80,000.00 for each count, with subsidiary imprisonment, and ordered her to indemnify the private complainant the total face value of the checks (₱40,002.00) plus interest. Petitioner failed to file a timely Notice of Appeal, opting instead for a Motion for Reconsideration, which was denied as a prohibited pleading under the Revised Rules on Summary Procedure. Her subsequent Notice of Appeal was also denied for being filed out of time. Her petitions for certiorari to the Regional Trial Court and the Court of Appeals were dismissed. The MeTC Decision thus became final and executory. Petitioner, acknowledging her procedural lapses, filed the instant petition for review on certiorari, seeking a liberal application of procedural rules to modify the penalty, which she contends is excessive and not in accordance with BP 22.

ISSUE

Whether the penalty imposed in the MeTC Decision, which is already final and executory, may still be modified.

RULING

Yes. The Supreme Court granted the petition and modified the penalty. The Court held that while the doctrine of finality and immutability of judgments generally applies, it is not an absolute rule. Procedural rules may be relaxed in the interest of substantial justice. The penalty imposed by the MeTC was erroneous. Under Section 1 of BP 22, for a check with a face value of ₱6,667.00, the maximum fine that may be imposed is double the amount of the check, or ₱13,334.00. The MeTC incorrectly computed the fine based on the aggregate face value of all six checks (₱40,002.00) instead of the individual face value per check, resulting in an excessive fine of ₱80,000.00 per count. Furthermore, the imposition of subsidiary imprisonment for non-payment of the fine was improper in light of Administrative Circular No. 12-2000 and the ruling in Vaca v. Court of Appeals, which prohibit subsidiary imprisonment if the fine is imposed as the sole penalty. The Court, citing its power to suspend its own rules to serve substantial justice, and considering that the case involves a penalty not authorized by law, modified the penalty. For each count of violation of BP 22, petitioner is sentenced to pay a fine of ₱13,334.00 (double the face value of each check). The order for subsidiary imprisonment in case of non-payment of the fine is deleted. The civil liability for the total amount of ₱40,002.00 plus 12% annual legal interest from September 21, 2002, until full payment is affirmed.