Case Digest (G.R. No. 141181) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On October 21, 1997, Samson Ching, a Chinese national and private complainant, filed eleven (11) criminal Informations under Batas Pambansa Blg. 22 (the “Bouncing Checks Law”) against Clarita S. Nicdao before the First Municipal Circuit Trial Court of Dinalupihan–Hermosa, Bataan. He alleged that Nicdao issued him undated Hermosa Savings Loan Bank checks amounting in the aggregate to ₱20,950,000.00 as security for loans she obtained from him beginning October 1995. When he later inscribed on those checks the dates and amounts and presented them on October 6–7, 1997, they were dishonored for “DAIF” (drawn against insufficient funds). After Nicdao pleaded not guilty, the MCTC convicted her on all counts (December 8, 1998), and the Regional Trial Court of Bataan, Branch 5, affirmed on May 10, 1999. Nicdao then appealed to the Court of Appeals (CA). In CA-G.R. CR No. 23055, the 13th Division on November 22, 1999, reversed and acquitted Nicdao of the eleven counts, finding (a) one ₱20 Case Digest (G.R. No. 141181) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Complaint
- On October 21, 1997, Samson Ching (petitioner) filed eleven (11) criminal complaints under BP 22 against Clarita Nicdao (respondent) for issuance of dishonored checks totaling ₱20,950,000.
- Checks were originally undated and blank as to payee and amount; respondent allegedly signed them as security for loans from October 1995 to 1997.
- Trial Proceedings
- Prosecution Evidence
- Petitioner Ching testified he lent respondent incremental sums up to ₱20,000,000 and secured repayment with blank checks, later dated October 6, 1997, then dishonored for “DAIF.”
- Bank teller Imelda Yandoc confirmed the eleven checks were stamped “DAIF” and that respondent’s account had insufficient funds (₱300 balance).
- Defense Evidence
- Respondent Nicdao denied indebtedness to Ching, stating she borrowed only ₱2,100,000 from Emma Nuguid (petitioner’s partner), fully paid by a ₱1,200,000 demand draft and daily cash payments noted on cigarette wrappers (₱5,780,000 total).
- Salesladies Melanie Tolentino and Jocelyn Nicdao corroborated that respondent’s pre-signed checks were stored in a cash box, filled out by them under Nuguid’s instruction, and one large check (₱20,000,000) had been missing since 1995.
- Case Disposition in Lower Courts
- MCTC (Dec. 8, 1998): Convicted respondent on all eleven counts; ordered her to pay ₱20,950,000 plus 12% interest.
- RTC (May 10, 1999): Affirmed MCTC convictions.
- CA – 13th Division (Nov. 22, 1999): Reversed and acquitted respondent, finding (a) the ₱20,000,000 check was stolen and undelivered, (b) other ten checks secured loans already extinguished by full payment.
Issues:
- Civil Liability
- Whether respondent Nicdao remains civilly liable to pay petitioner Ching ₱20,950,000 despite acquittal.
- Consolidation of Appellate Cases
- Whether the CA committed reversible error by not consolidating CA-G.R. CR No. 23055 (Ching’s case) with CA-G.R. CR No. 23054 (Nuguid’s case).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)