GR 261807; (August, 2024) (Digest)
G.R. No. 261807, August 14, 2024
TEDDY PEÑA Y ROMERO, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.
FACTS
Petitioner Teddy Peña y Romero was convicted for slight physical injuries and unjust vexation and meted a straight penalty of 15 days of arresto menor with PHP 5,000.00 moral damages for slight physical injuries, and a straight penalty of 15 days of arresto menor with a PHP 200.00 fine for unjust vexation. The Court, by a Resolution dated February 8, 2023, denied his petition and affirmed the verdict of conviction. Peña subsequently filed a Motion for Reconsideration, imploring the Court to modify his penalty from imprisonment to community service. The trial court’s decision was promulgated on June 29, 2016, while Republic Act No. 11362 (the Community Service Act) took effect on August 8, 2019, and the Guidelines for the Community Service Act under A.M. No. 20-06-14-SC took effect on November 2, 2020.
ISSUE
Whether petitioner Teddy Peña y Romero may avail of the benefits under Republic Act No. 11362 (Community Service Act) to render community service in lieu of imprisonment for his penalties of arresto menor, despite the law’s enactment after the promulgation of judgment in his case.
RULING
Yes. The motion for reconsideration is granted. The Court’s Resolution dated February 8, 2023 is affirmed with modification. While laws are generally prospective in application, penal laws which are favorable to the person guilty of the felony who is not a habitual criminal are given retroactive effect under Article 22 of the Revised Penal Code. The benefits under Republic Act No. 11362, being more favorable to Peña, can be availed by him retroactively. The imposition of community service in lieu of imprisonment is a discretionary privilege of the court, not a matter of right. Due to the unavailability of the option to apply for community service before the trial court, the Regional Trial Court, and the Court of Appeals, Peña may validly apply for the conversion of his sentence at the first instance before this Court.
ACCORDINGLY:
1. In Criminal Case No. 14-09861, petitioner Teddy Peña y Romero is found GUILTY of slight physical injuries and is ORDERED to render COMMUNITY SERVICE IN LIEU OF IMPRISONMENT and to PAY moral damages of PHP 5,000.00.
2. In Criminal Case No. 14-09862, petitioner Teddy Peña y Romero is found GUILTY of unjust vexation and is ORDERED to render COMMUNITY SERVICE IN LIEU OF IMPRISONMENT and to PAY a FINE of PHP 200.00.
The Branch 32, Metropolitan Trial Court, Quezon City, is directed to conduct hearings to determine the number of hours and the period for the community service under the supervision of a probation officer. The monetary awards shall earn 6% legal interest per annum from finality until fully paid.