RONALD SORIANO, PETITIONER, VS. COURT OF APPEALS, RESPONDENTS.

G.R. No. 123936, March 4, 1999

FACTS:

Petitioner Ronald Santiago was convicted of reckless imprudence resulting in homicide, serious
physical injuries, and damage to property on December 7, 1993. He was granted probation on March 8,
1994, with conditions including meeting family responsibilities, specific employment, and
indemnification of the victim's heirs.

A motion to cancel probation was filed on April 26, 1994, citing failure to satisfy civil liability
and a supplemental motion alleging another crime. The trial court denied the motion but directed
petitioner to submit a payment program.

Probation officer Nelda D. Maycong later discovered that petitioner's father, the vehicle owner,
received insurance payment but did not turn it over to the victim's heirs. The trial court ordered petitioner
to explain non-compliance, and a subsequent motion for reconsideration was filed.

The trial court declared petitioner in contempt on October 4, 1994, revoking probation and
ordering his arrest. The Court of Appeals upheld this decision, citing petitioner's "stubborn unwillingness"
to comply.

ISSUE:

Whether or not the trial court erred in finding deliberate refusal to comply with orders and
revoking probation.

RULING:

No. The trial court did not err in finding deliberate refusal. Petitioner received notice of the
orders, and his refusal to comply is evident. Satisfaction of civil liability is not a condition precedent to
probation but a requirement for its continued enjoyment. Petitioner's poverty is not a valid excuse, as he
was given a chance to formulate a payment program based on his needs and capacity.

Petitioner's reliance on Salgado is misplaced, as his case involves submitting his own payment
program, not an imposed one. His continued refusal to submit a program creates the impression of
avoiding payment, which is impermissible.

The trial court's requirements align with statutory conditions, and petitioner, having violated
them, cannot challenge probation revocation. Probation is a privilege subject to court discretion, and
revocation is justified when conditions are not met. Petitioner, having squandered the opportunity, must
face the consequences.

The petition is denied, and the Court of Appeals decision is affirmed.