Facts:

The case involves Rosario M. Apacible as the petitioner and the People of the Philippines along with San Miguel Corporation (SMC), represented by Attorney-in-Fact Leon B. Liza, Jr., as respondents. The events leading to this case began in 1999 when Apacible entered into a dealership agreement with SMC, allowing her to distribute San Miguel products in Nasugbu, Batangas, and surrounding areas. However, due to her failure to meet her financial obligations, SMC terminated the contract. On December 16, 1999, Apacible acknowledged her debt to SMC amounting to P3,957,173.60, which included the unpaid balance of returned checks. To settle this debt, she issued eight post-dated checks, four of which were the subject of the criminal charges against her.

When SMC deposited these checks upon maturity, they were dishonored due to insufficient funds and a closed account. Despite several demand letters sent to Apacible, she failed to fulfill her obligations, prompting SMC to file a compl...

Facts:

Background of the Case

• Rosario M. Apacible (petitioner) and San Miguel Corporation (SMC) entered into a dealership agreement in 1999, authorizing Apacible to deliver San Miguel products in Nasugbu, Batangas, and other municipalities.
• SMC terminated the contract due to Apacible's delinquency in paying her obligations. Apacible executed an Undertaking on December 16, 1999, acknowledging her indebtedness to SMC in the amount of P3,957,173.60, representing unpaid balances of returned checks.
• As payment, Apacible issued eight post-dated checks, four of which were dishonored due to "insufficiency of funds" and "account closed."

Legal Proceedings

• SMC filed a complaint-affidavit against Apacible, leading to four Informations for violation of Batas Pambansa Bilang 22 (B.P. 22) filed on July 31, 2003.
• Apacible filed a Demurrer to Evidence on November 4, 2011, which the Municipal Trial Court in Cities (MTCC) granted on February 21, 2012, acquitting her of criminal liability due to insufficient evidence. However, the MTCC ruled that the civil aspect of the case would continue.
• Apacible filed multiple motions challenging the MTCC's jurisdiction over the civil aspect, arguing that the P2,000,000.00 claim was beyond the MTCC's jurisdiction. These motions were repeatedly denied.
• On April 8, 2014, the MTCC found Apacible civilly liable to SMC and ordered her to pay the value of the dishonored checks plus 12% interest per annum from July 31, 2003, until fully satisfied.
• Apacible appealed to the Regional Trial Court (RTC), which affirmed the MTCC's decision on June 9, 2015. The RTC ruled that SMC was not responsible for the nonpayment of docket fees and allowed the fees to be a lien on the judgment.
• Apacible further appealed to the Court of Appeals (CA), which dismissed her petition on November 23, 2016, and denied her motion for reconsideration on July 6, 2017.

Key Issues Raised by Apacible

• Apacible argued that the MTCC lacked jurisdiction over the civil aspect of the case due to the nonpayment of docket fees.
• She also claimed that the P2,000,000.00 claim exceeded the MTCC's jurisdictional limit.
• Apacible raised the issue of jurisdiction for the first time in her Supplemental Appeal Memorandum filed with the RTC, 11 years after the Informations were filed.

---

Issue:

1. Whether the MTCC acquired jurisdiction over the civil aspect of the case despite the alleged nonpayment of docket fees.
2. Whether Apacible is barred by laches from raising the issue of jurisdiction due to her active participation in the proceedings and failure to raise the issue seasonably.
3. Whether the MTCC had jurisdiction over the P2,000,000.00 claim, given its jurisdictional limit.

---

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Conclusion:

The Supreme Court upheld the lower courts' rulings, finding Apacible civilly liable to SMC for the dishonored checks. The Court emphasized that Apacible's active participation in the proceedings and her failure to raise the issue of jurisdiction seasonably barred her from challenging the MTCC's jurisdiction. The civil liability was properly adjudicated, and the docket fees were treated as a lien on the judgment.