Title
Campos vs. People
Case
G.R. No. 187401
Decision Date
Sep 17, 2014
Campos issued dishonored checks for a loan, convicted under B.P. 22; SC upheld conviction, rejecting good faith defense and affirming notice of dishonor.
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Case Digest (G.R. No. 187401)

Facts:

  1. Loan and Issuance of Checks: On March 17, 1995, Ma. Rosario P. Campos (Campos) obtained a loan of P50,000.00 from First Women’s Credit Corporation (FWCC), payable in installments. She issued several postdated checks to cover the installment payments.
  2. Dishonored Checks: Fourteen (14) checks issued by Campos, drawn against her BPI Family Bank account, were dishonored due to a "closed account." The checks totaled P46,666.62 and were dated from August 15, 1995, to February 28, 1996.
  3. Legal Proceedings: Campos was charged with 14 counts of violating Batas Pambansa Bilang 22 (B.P. 22), also known as the Bouncing Checks Law. She was tried in absentia after failing to attend court proceedings post-arraignment.
  4. Conviction: The Metropolitan Trial Court (MeTC) convicted Campos on December 7, 1999, sentencing her to six (6) months imprisonment for each violation and ordering her to indemnify FWCC P46,666.62 plus legal interest.
  5. Appeals: Campos appealed to the Regional Trial Court (RTC), which upheld her conviction. She further appealed to the Court of Appeals (CA), which also affirmed the RTC’s decision. Her motion for reconsideration was denied.

Issue:

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Ruling:

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Ratio:

  1. Knowledge of Insufficient Funds: Under B.P. 22, knowledge of insufficient funds is presumed when a check is dishonored. The issuer must pay the amount due or make arrangements for payment within five (5) banking days after receiving notice of dishonor.
  2. Proof of Notice of Dishonor: While registry return receipts alone are insufficient to prove receipt of a notice of dishonor, Campos’ admission of making payment arrangements confirmed her receipt of the notice.
  3. Good Faith and Equity: Good faith is not a defense unless the issuer fully complies with the requirements of B.P. 22, such as making arrangements for payment within the prescribed period. Campos failed to meet this requirement.
  4. Finality of Conviction: The Court found no cogent reason to reverse the lower courts’ rulings, as Campos’ conviction was supported by evidence and legal principles.


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