G.R. No. 103287-88 - People vs. Machete

On 16 August 2001, Raffy Brodeth and Rolan B. Onal (petitioners) were charged before MeTC Manila Branch 30 with two counts of violating Batas Pambansa Blg. 22 for issuing bounced checks:

Check No. 2700111416 (5 September 1999) for ₱123,600.00 payable to Vill Integrated Transport Corp. (represented by Abraham G. Villegas)
Check No. 2700111415 (31 August 1999) for ₱140,000.00 payable to the same payee

The checks were dishonored for “Drawn Against Insufficient Funds (DAIF).” Notices of dishonor were sent, but the petitioners failed to pay or arrange payment within five banking days.

Vill Integrated (complainant) provided equipment and tugboats to Land & Sea Resources Phils., Inc. (L&S Resources) under service contracts starting August 1999.
L&S Resources made partial payments, including three Metrobank checks; two of these are the subject checks which bounced.
Demand letters dated 9 October 1999 and 3 May 2000 were sent for outstanding balances and dishonored checks; no settlement followed, prompting the criminal complaint on 23 November 2000.

Brodeth claimed in a 2008 counter-affidavit that the bounced checks were paid in cash, fuel oil, and food for crew, and that obligations actually belonged to one Noli Dela Cerna.
Onal’s letter (10 November 1999) purportedly advised Vill Integrated to bill Dela Cerna instead.
Petitioners offered a photocopied letter (Exh. “2”) as proof of payment but failed to present the original or any receipts.

MeTC (2 July 2008): Found petitioners guilty beyond reasonable doubt, emphasizing prima facie proof of dishonor (“DAIF”) and petitioners’ admission of receipt of demand letters. Imposed fines of ₱200,000 per count, subsidiary imprisonment if insolvent, civil indemnity of ₱283,600, and costs.
RTC Manila Branch 27: Affirmed MeTC decision in toto, holding jurisdiction based on Villegas’s affidavit allegation that checks were issued in Manila and validating the presumption of knowledge from receipt of dishonor notices.
CA (17 May 2011 Decision; 20 July 2011 Resolution): Denied petitioners’ appeal. Reiterated that the offense is the issuance of a bouncing check regardless of purpose and upheld MeTC’s jurisdiction on affidavit-complaint’s “in Manila” statement.

Whether the MeTC of Manila had territorial jurisdiction over the violation of B.P. Blg. 22 cases.
Whether the presumption of petitioners’ knowledge of insufficient funds was erroneously applied absent proof of corporate fund knowledge.
Whether petitioners’ guilt was proven beyond reasonable doubt given their defense of payment and lack of direct evidence of dishonor knowledge.