G.R. No. L-8327; March 28, 1913
THE UNITED STATES, plaintiff-appellee, vs. WILLIAM C. HART, C.J. MILLER, D.P. DUNN, and SERVILIANO NATIVIDAD, defendants.

FACTS

The defendants were charged with violating the gambling law ( Act No. 1757 ). They pleaded guilty, and on July 20, 1912, the court sentenced William C. Hart to pay a fine of P30 and the other defendants P15 each, which they immediately paid. Subsequently, on July 31, 1912, the provincial fiscal filed a motion informing the court that the Constabulary had seized a sum of money at the gambling site and requested the court to modify its decision regarding that money. On October 4, 1912, the court, citing Article 345 of the Penal Code, ordered the confiscation of the seized money. Defendants Hart and Natividad appealed, arguing the court could not amend a final judgment and that the confiscation was erroneous.

ISSUE

Whether the lower court erred in amending its final judgment to order the confiscation of the seized money after the defendants had already served their sentence by paying the fines imposed.

RULING

Yes. The Supreme Court reversed the order of confiscation. The judgment of July 20, 1912, became final upon the defendants’ compliance by paying the fines. A court cannot modify, alter, or impose an additional penalty after a sentence has become final. The confiscation order constituted an additional penalty. The Court found it unnecessary to rule on the applicability of Article 345 of the Penal Code to violations of Act No. 1757 , as the amendment of the final judgment was itself reversible error.