Case Digest (G.R. No. 196853) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Robert Chua vs. People of the Philippines (G.R. No. 196853, July 13, 2015), petitioner Robert Chua, a businessman of Quezon City, issued fifty-four post-dated PSBank checks between August and December 1993 to his friend and neighbor, Philip See, under a rediscounting arrangement. When See deposited the checks, they were dishonored for insufficient funds or closed account. See sent a demand letter dated December 10, 1993, but Chua did not make payment. On December 23, 1993, See filed a complaint before the Quezon City Prosecutor’s Office for violation of Batas Pambansa Blg. 22 (BP 22). Probable cause was found on April 25, 1994, and fifty-four counts were filed before the Metropolitan Trial Court (MeTC). During trial, Chua successfully objected to the admissibility of the December 10, 1993 letter as it was a photocopy lacking proof of receipt. Years later, the prosecution sought to reopen its case and admit a “newly-discovered” demand letter dated November 30, 1993 bearing Chu Case Digest (G.R. No. 196853) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Robert Chua (petitioner) and Philip See (private complainant) were long-time friends and neighbors who entered into a rediscounting arrangement at 3% interest.
- From August to December 1993, Chua issued 54 postdated PSBank checks to See, totaling various amounts, in connection with their arrangement.
- Dishonor and Procedural History
- When See deposited the checks, they were dishonored for insufficient funds or closed account.
- See sent a demand letter dated December 10, 1993 (photocopy as Exhibit B), which Chua denied receiving, and later discovered a November 30, 1993 demand letter.
- Criminal complaints for 54 counts of violating Batas Pambansa Blg. 22 (BP 22) were filed; trial courts admitted the November 30, 1993 letter as evidence despite objections and Chua’s demurrer.
- Metropolitan Trial Court (MeTC), Regional Trial Court (RTC), and Court of Appeals (CA) all convicted Chua based on:
- Issuance and dishonor of the checks.
- Presumed knowledge of insufficient funds from receipt of the November 30, 1993 demand letter and failure to pay within five banking days.
Issues:
- Whether the lower courts erred in presuming Chua received the November 30, 1993 demand letter on its date and thus establishing the five-day period for BP 22’s knowledge presumption.
- Whether the November 30, 1993 demand letter was properly considered a “newly discovered evidence” justifying its admission.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)