Case Digest (G.R. No. 187401)
Facts:
The case involves Ma. Rosario P. Campos (petitioner) against the People of the Philippines and First Women’s Credit Corporation (respondents). The events leading to the case began on March 17, 1995, when Campos secured a loan of P50,000.00 from the First Women’s Credit Corporation (FWCC), which was to be repaid in installments. To facilitate this, she issued several postdated checks to cover her installment payments. However, fourteen of these checks, drawn against her account at BPI Family Bank, were dishonored due to insufficient funds, as the account was closed. The specific checks involved were dated from August 15, 1995, to February 28, 1996, totaling P46,666.62. After Campos failed to settle her obligations despite demands from FWCC, she was charged with fourteen counts of violating Batas Pambansa Bilang 22 (B.P. 22), known as The Bouncing Checks Law, before the Metropolitan Trial Court (MeTC) of Pasay City. Campos was tried in absentia after she did not attend the cour...
Case Digest (G.R. No. 187401)
Facts:
- 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.
- 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.
- 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.
- 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.
- 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:
- 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.
- 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.
- 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.
- 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.