Modification despite entry of judgment

Modification despite entry of judgment | Daily Tribune

The Supreme Court affirmed the decision of the Court of Appeals convicting the petitioner in this case. He subsequently filed a motion for reconsideration. The Highest Court denied it, declaring that no further submissions from him would be entertained and ordering the Entry of Judgment.

An entry of judgment, which means a decision has become final and executory, was indeed made that day. Accordingly, the accused must already serve his sentence. Despite this, the petitioner filed a second motion for reconsideration. Among the issues he raised was the recomputation of his sentence in view of the passage of a law that would shorten his sentence, while his case was pending.

The Supreme Court, in denying the other prayers in his second motion for reconsideration, accorded merit to this particular ground.

Thus, it declared that, “Time and again, the Court has repeatedly held that ‘a decision that has acquired finality becomes immutable and unalterable, and may no longer be modified in any respect, even if the modification is meant to correct erroneous conclusions of fact and law, and whether it be made by the court that rendered it or by the Highest Court of the land.

“This principle, known as the doctrine of immutability of judgment, has a two-fold purpose, namely: (a) to avoid delay in the administration of justice and thus, procedurally, to make orderly the discharge of judicial business; and (b) to put an end to judicial controversies, at the risk of occasional errors, which is precisely why courts exist.

“However, this doctrine is not a hard and fast rule as the Court has the power and prerogative to relax the same in order to serve the demands of substantial justice considering: (a) matters of life, liberty, honor, or property; (b) the existence of special or compelling circumstances; (c) the merits of the case; (d) a cause not entirely attributable to the fault or negligence of the party favored by the suspension of the rules; (e) the lack of any showing that the review sought is merely frivolous and dilatory; and (f) that the other party will not be unjustly prejudiced thereby.

“The second motion merely asks that the Court readjust petitioner’s prison sentence in accordance with RA 10951, which was enacted in 2017. As may be gleaned from the law’s title, it adjusted the value of the property and the amount of damages on which various penalties are based, taking into consideration the present value of money, as opposed to its archaic values when the RPC was enacted in 1932. While it is conceded that petitioner committed the crime for which he was convicted way before the enactment of RA 10951, this law expressly provides for retroactive effect if it is favorable to the accused.

“To recall, petitioner was found guilty beyond reasonable doubt of Estafa for having defrauded private complainant in the amount of P2,050,000. As such, he was sentenced to suffer the penalty of imprisonment for an indeterminate period of four years and two months of prison correccional, as minimum, to 20 years of reclusion temporal, as maximum.

“Notably, the computation of this penalty was based on the schedule of penalties stated in Article 315 of the RPC, prior to the enactment of RA 10951. However, due to the enactment of RA 10951—which readjusted the graduated values for which the penalties for Estafa are based—the prescribed penalty for Estafa involving the aforementioned defrauded amount was significantly lowered.

“At this juncture, it is well to stress that in Bigler v. People (Bigler), the Court ruled that notwithstanding the finality of a criminal conviction, it still has the power to correct the penalty imposed against an accused-convict, if it finds the same to be outside the range prescribed by law. In this regard, the Court further elucidated that ‘a sentence which imposes upon the defendant in a criminal prosecution a penalty in excess of the maximum which the court is authorized by law to impose for the offense for which the defendant was convicted, is void for want or excess of jurisdiction as to the excess.’

“Thus, in view of the Court’s pronouncement in Bigler, the provisions of RA 10951, the Indeterminate Sentence Law, and considering further the absence of any mitigating or aggravating circumstances, the proper penalty to be imposed on petitioner should be four months and 20 days of arresto mayor, as minimum, to two years, 11 months, and 10 days of prison correccional, as maximum.

“In sum, the Court deems it proper to lift the Entry of Judgment dated 14 January 2019 in order to modify the penalty imposed on petitioner as explained above. Notably, this reduction of penalty entitles petitioner to apply for probation, pursuant to RA 10707, which allows an accused-convict to apply for probation in the event that he/she is sentenced to a non-probationable penalty by the trial court but subsequently modified by the appellate court to a probationable penalty.”

The facts and quoted redacted portion of the decision are from S.C. G.R. No. 226615 promulgated on 13 January 2025.