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JULIE S. SUMBILLA v. MATRIX FINANCE CORPORATION

FACTS:

Petitioner Julie S. Sumbilla obtained a cash loan from respondent Matrix Finance Corporation. As partial payment for her loan, petitioner issued six Philippine Business Bank checks with a uniform face value of P6,667.00 each. However, all the checks were dishonored as they were drawn against a closed account. Petitioner was indicted for six counts of violation of Batas Pambansa Blg. 22 (BP 22). The Metropolitan Trial Court (MeTC) found petitioner guilty and imposed a penalty of fine amounting to P80,000.00 for each count, with subsidiary imprisonment. Petitioner failed to timely file an appeal and her conviction became final. Petitioner filed a petition for certiorari before the Regional Trial Court (RTC), but it was dismissed. Petitioner then filed a petition for review before the Court of Appeals (CA), which ruled that the correct remedy is an ordinary appeal. The CA denied petitioner's motion for reconsideration, after which petitioner filed a motion for extension of time to file a petition for review on certiorari. Petitioner filed the petition within the granted extension. Petitioner argues that the penalty imposed by the MeTC is excessive and in violation of existing law and jurisprudence. The MeTC imposed a fine of P80,000.00 for each count, which is more than 11 times the amount of the face value of each dishonored check. The checks have a face value of P6,667.00 each, and the maximum penalty prescribed by BP 22 is double the face value of the check. The MeTC incorrectly computed the fine using the total face value of the six checks, instead of the face value of each check.

ISSUES:

  1. Whether the penalty imposed in the MeTC Decision dated January 14, 2009, which is already final and executory, may still be modified.

RULING:

  1. Yes, the penalty may still be modified. The Supreme Court ruled that the finality and immutability of judgments are not strict and unyielding rules. The Court has the discretion to relax procedural rules to serve substantial justice. The penalty of a fine of P80,000.00 per count imposed by the MeTC was corrected to P13,334.00 per count, aligning with the maximum penalty prescribed under Section 1 of BP 22.

PRINCIPLES:

  1. Doctrine of Finality and Immutability of Judgments A decision that has acquired finality becomes immutable and unalterable but is not an absolute rule.

  2. Liberal Application of Procedural Rules Procedural rules should aid the attainment of justice, and the Court can relax them in the interest of substantial justice.

  3. Maximum Penalty Under BP 22 The maximum penalty of fine for violating BP 22 is double the amount of the dishonored check but not exceeding P200,000.00.

  4. Administrative Circulars on Subsidiary Imprisonment Administrative Circular Nos. 12-2000 and 13-2001 prescribe a rule of preference for fines over imprisonment but do not remove the possibility of subsidiary imprisonment in BP 22 cases.

  5. Constitutional Prohibition on Imprisonment for Debt BP 22 does not violate the constitutional prohibition against imprisonment for debt as it penalizes the issuance of worthless checks rather than the non-payment of an obligation.