People v. Salvador Alapan

Summary

This Supreme Court case arose from eight BP Blg. 22 convictions where the accused was fined but no subsidiary imprisonment was provided in the judgment. When the private complainant sought subsidiary imprisonment for nonpayment, the Court ruled that: (1) private complainants lack standing to appeal criminal aspects - only the OSG can represent the State; (2) subsidiary imprisonment must be expressly stated in the conviction judgment and cannot be imposed retroactively; and (3) final judgments are immutable except for clerical errors, nunc pro tunc entries, or void judgments. The decision emphasizes due process protections and the separation between civil and criminal aspects of cases, affirming that private parties cannot control criminal proceedings contrary to the Solicitor General's position.