People v. Subido

Summary

This criminal libel case clarified the scope of subsidiary imprisonment under the Revised Penal Code. Subido was convicted of libeling Mayor Lacson and sentenced to imprisonment, fine, and indemnity with subsidiary imprisonment for non-payment. The Court of Appeals eliminated the imprisonment penalty but kept the fine and reduced indemnity. The Supreme Court held that subsidiary imprisonment remained applicable through the CA's general affirmance, but applied the retroactive benefit of RA 5465 which amended Article 39 to exempt accused persons from subsidiary imprisonment for civil liability. The decision established that while subsidiary imprisonment still applies to criminal fines, it no longer applies to civil indemnity due to the favorable amendment. The case demonstrates the principle that penal statutes should be construed liberally in favor of the accused and that beneficial amendments apply retroactively even to final judgments.