G.R. No. 248306 - Republic vs. Science Park of the Philippines, Inc.

Leodegario Bayani, the petitioner, was charged with violating Batas Pambansa Blg. 22 for issuing a bouncing check.
On or about August 20, 1992, Bayani issued Check No. 054924, which was dated August 26, 1992, drawn to “Cash” for the amount of ₱10,000.00.
It was established that Bayani knew at the time of issuance that he did not have sufficient funds or credit in his account with the Philippine Savings Bank (PS Bank), Candelaria Branch, to cover the check.
The check was subsequently dishonored by the bank due to insufficient funds; Bayani’s account, closed on September 1, 1992, had only ₱2,414.96 remaining.

The Regional Trial Court (RTC) of Lucena City, Branch 55, convicted Bayani beyond reasonable doubt.
The RTC found that:

The check was part of a check booklet issued on December 12, 1991, by PS Bank.
The check was postdated and went through the usual process of presentation, deposit, and subsequent return due to insufficient funds.
Confrontations occurred between the complaining witness, Dolores Evangelista, Bayani, and Alicia Rubia—who was involved in the exchange of the check for cash.

The RTC sentenced Bayani to one (1) year of imprisonment, imposed a fine of ₱5,000.00, ordered him to reimburse the value of the check (₱10,000.00), pay attorney’s fees amounting to ₱5,000.00, and double the cost of the suit.

The Court of Appeals (CA) affirmed the RTC’s decision in toto on January 30, 2002.
The CA held that both the circumstances of the offense and the evidence against Bayani were sufficient to overcome defenses, including those alleging reliance on hearsay and insufficiency of evidence regarding consideration.

The reliance on hearsay evidence—specifically, the testimony of Dolores Evangelista regarding what Alicia Rubia allegedly told her.
The argument that the evidence failed to sufficiently prove that the check was issued for “valuable consideration.”
The contention that the conviction rested on presumptions rather than on solid, independent evidence.

The check’s inclusion in the booklet issued by PS Bank bearing Bayani’s name.
Testimony regarding the encounters between Bayani, Evangelista, and Rubia, which indirectly confirmed Bayani’s involvement.
The fact that Bayani did not categorically deny that the signature on the check was his, though he noted differences from his usual signature.

The key hearsay issue revolved around Evangelista’s testimony relaying what Rubia purportedly told her regarding Bayani’s request to exchange the check for cash.
The court noted that:

Evangelista’s statement was deemed hearsay because it was not based on her direct knowledge but on Rubia’s assertion.
Bayani waived his right to object to this hearsay evidence by failing to raise a timely objection during the trial, thereby rendering the evidence admissible.

The prosecution maintained that a check, by its very nature under the Negotiable Instruments Law, is presumed to be issued for valuable consideration unless the contrary is proven.
The fact that the check was exchanged for cash was deemed sufficient to meet the element of valuable consideration, despite Bayani’s arguments to the contrary.

The Court found that the cumulative evidence, including the admitted hearsay and the presumption of consideration, sufficiently established Bayani’s guilt beyond reasonable doubt.
The conviction was thereby upheld on the basis that the factual findings of the trial and appellate courts were supported by the evidence on record.

Whether the issuance of a postdated, bouncing check by Bayani, knowing that his account had insufficient funds, constitutes a violation of Batas Pambansa Blg. 22.

Whether the evidence presented was sufficient to establish that Bayani knowingly issued a check that could not be honored.
The extent to which Bayani’s partial denial regarding the signature impacts his liability.

Whether the Court of Appeals erred in upholding the conviction despite the petitioner’s claims regarding hearsay evidence.

Whether the failure to object in a timely manner to the hearsay testimony of Dolores Evangelista precluded its exclusion.
Whether the accepted hearsay can be given any evidentiary weight against Bayani.

Whether the prosecution adequately established that the check was issued for valuable consideration.

If the presumption of issuance for valuable consideration stands unrefuted by Bayani’s arguments.
Whether exchanging the check for cash inherently satisfies the requirement for valuable consideration under the law.