NORMA DE JOYA, 

PETITIONER, vs. THE JAIL WARDEN OF
BATANGAS CITY AND HON. RUBEN A. GALVEZ AS PRESIDING
JUDGE OF BATANGAS CITY MUNICIPAL TRIAL COURT IN
CITIES, BRANCH I, RESPONDENTS.
G.R. No. 107383 | February 20, 1996 | MENDOZA, J.
Digest by: BALAYAN
Facts of the Case:
 In two separate cases, the petitioner was charged with violations of
Batas Pambansa Blg. 22 (Bouncing Checks Law or the Anti-
Bouncing Checks Law).
The circular merely establishes a rule of preference in the application
of penalties for B.P. Blg. 22 violations. The court has discretion in
determining the appropriate penalty, considering the circumstances of the
offense and the offender. In this case, the petitioner did not present evidence
during the trial, and the judgment against her became final and executory.
Dispositive Portion:
IN LIGHT OF ALL THE FOREGOING, the petition is DISMISSED for
lack of merit.
SO ORDERED.

 The trial court found the petitioner guilty in both cases and imposed
a sentence of imprisonment and indemnification.

 The petitioner failed to appear during the trial and jumped bail. The
decisions in both cases were promulgated in absentia.

 The petitioner remained at large for several years until her arrest.

 She filed a motion to apply Supreme Court Administrative Circular

No. 12-2000 retroactively and to order her release from detention,
but the trial court denied the motion.

 The petitioner now seeks the Court's intervention to declare her

detention illegal and secure her release.

Issue of the Case:

Whether or not the petitioner is entitled to the writ of habeas corpus?
The Ruling of the Court:
The petitioner's plea for a writ of habeas corpus is without merit. The
petitioner was arrested and detained based on a final judgment convicting her
of a violation of B.P. Blg. 22. Therefore, she is not entitled to a writ of habeas
corpus. The petitioner's reliance on SC Admin. Circular No. 12-2000 is
misplaced, as it does not apply retroactively to cases already terminated by
final judgment.