Non-Imprisonment for Debts

Question 1

Sec. 20, Art. III.

No person shall be imprisoned for _____ or non-payment of _________.

Answer 1

debt;

poll tax

Question 2

What is a debt?

Answer 2

Debt – any civil obligation arising from a contract. It includes even debts obtained through fraud since no distinction is made in the Constitution

[Ganaway v. Quillen, G.R. No. L-18619 (1922)].

Question 3

What is a poll tax?

Answer 3

a specific sum levied upon any person belonging to a certain class without regard to property or occupation (e.g. community tax).

Question 4

May a person be imprisoned as a penalty for a crime arising from a contractual debt and imposed in a proper criminal proceeding?

Answer 4

YES.

A person may be imprisoned as a penalty for a crime arising from a contractual debt and imposed in a proper criminal proceeding. Thus, the conversion of a criminal fine into a prison term does not violate the right to non-imprisonment for debts because in such a case, imprisonment is imposed for a monetary obligation arising from a crime [Ajeno v Judge Insero, A.M. No. 1098-CFI (1976)].