G.R. No. 116962 - Caca vs. Court of Appeals

Maria Socorro Caca, the petitioner, was charged with estafa and violation of Batas Pambansa Blg. 22 (BP 22) for allegedly issuing a postdated check in favor of Nancy Lim Rile.
The case involved multiple alleged transactions in which checks were issued as security for loans but later became the subject of dispute when one of the checks was dishonored.

On December 16, 1987, petitioner allegedly borrowed ₱50,000.00 from Rile and secured the transaction with a postdated check, which was redeemed in cash before its due date.
A subsequent transaction on March 22, 1988, involved a loan of ₱125,000.00, again secured by another postdated check that was redeemed prior to its maturity.
On August 17, 1988, petitioner purportedly secured a third loan amounting to ₱250,000.00 with Check No. 201596, drawn on the Security Bank and Trust Co. and postdated February 28, 1989.

Unlike the previous transactions, the third check was not redeemed by petitioner before its due date.
Rile deposited the check with China Bank (Magallanes Branch, Cebu City) and it was dishonored for being drawn against a closed account.
Despite several demand letters issued by Rile, petitioner failed to settle the alleged obligation.

Petitioner denied issuing the check for any account of Rile.
She asserted that she never received ₱250,000.00 nor entered into any borrowing transaction with Rile, emphasizing her financial incapacity to incur or repay such an obligation.
Petitioner argued that the check in question, which was pre-signed and allegedly kept in her drawer as a bank teller at Traders Royal Bank (TRB), had been lost and later wrongfully manipulated by Rile, who “typed in” the payee, date, and amount.

Placido Villarosa, a security guard at TRB, testified that the bank logbook did not record petitioner leaving the building on August 17, 1988, thereby undermining the alleged transaction.
Exaltation Saynes, attesting to the petitioner’s financial condition, claimed that her sister (the petitioner) was not financially capable of borrowing and repaying such sums.
Sarah Alfonso, petitioner’s officemate, corroborated receiving a demand letter from Rile and confirmed that petitioner had no dealings with Rile, adding weight to the assertion of a swindle by a third party (Annie Pascua).
Additional details revealed that petitioner had previously issued pre-signed checks to a co-employee, Luana Sumalinog, and while petitioner suggested Sumalinog might have been involved in misappropriating the check, no legal action was taken against her.

On March 12, 1992, Judge Celso M. Gimenez of the Regional Trial Court, Cebu City, Branch 5, rendered a judgment finding petitioner guilty solely of the violation of BP 22.
The judgment imposed a six-month imprisonment and mandated the payment of ₱250,000.00 plus legal interest from the filing of the case until full settlement.
The Court of Appeals affirmed the judgment in toto on June 30, 1994.
The petitioner’s appeal primarily contested the trial court’s appreciation of the evidence, particularly the credibility of witness testimonies.

Whether the trial court properly appreciated and gave due deference to its findings on the credibility of the witnesses.
Whether the affirmative accounts by Rile and other witnesses were entitled to precedence over petitioner’s denials.

Whether petitioner’s categorical denial of initiating any transaction with Rile, including her contention of not receiving any loan amount, holds merit in light of the corroborative evidence.
Whether the negative defense based solely on denial can outweigh affirmative testimonies and documentary records.

Whether the petitioner’s claim of lacking financial capability is a valid defense against entering into or repaying a borrowing, given that financial distress itself may force one to borrow.

Whether the possibility that the pre-signed check was stolen or misappropriated (involving Luana Sumalinog) could reasonably exculpate petitioner, despite the absence of any legal action against the alleged culprit.