People v. Aparejado (Perfecto Bravo)

Summary

This Supreme Court decision established that serving subsidiary imprisonment for non-payment of a criminal fine completely extinguishes the civil liability for that fine under Article 39, Rule 5 of the Revised Penal Code. Perfecto Bravo, convicted of illegal fishing by dynamite, served both his imprisonment and subsidiary imprisonment for an unpaid P200 fine. Five years later, when authorities attempted to attach his property to collect the fine, the Supreme Court ruled the attachment illegal since the civil liability was already extinguished. The Court distinguished between the extinguished fine and the still-payable court costs, emphasizing that the defective attachment improperly combined both obligations. This case clarifies the legal effects of subsidiary imprisonment in criminal cases and the limits of post-conviction enforcement procedures.