Facts:

This case involves the petitioner, John Dennis G. Chua, who faced allegations of four counts of violation of Batas Pambansa Bilang 22, as filed by respondents People of the Philippines and Cristina Yao. It stemmed from a series of loans initiated by Yao to Chua, which occurred between January and June 2001, comprising a total of P6 million. In return for these loans, Chua issued four checks, which subsequently bounced due to being drawn against a closed account. Following the dishonor of these checks, Yao sent a demand letter to Chua, which was reportedly received by his secretary.

The case was initially filed in the Metropolitan Trial Court (MeTC) of San Juan City, presided over by Judge Elvira DC Castro, where Chua entered a plea of not guilty on September 16, 2004. After various proceedings, including mediation and trial, Judge Philip Labastida took over as presiding judge in 2007. Due to Labastida's death in December 2008, Judge Marianito C. Santos was designated as the

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Facts:

Background and Loan Transaction

• Petitioner John Dennis G. Chua became involved with respondent Cristina Yao through his mother, who mentioned plans to revive their sugar mill business in Bacolod City.
• In response, Yao lent petitioner substantial sums on multiple occasions:
• P1 million on January 3, 2001;
• P1 million on January 7, 2001;
• P1.5 million on February 16, 2001; and
• An additional P2.5 million in June 2001.
• As payment for these loans, petitioner issued four checks corresponding to the amounts, but all were dishonored due to being drawn on a closed account.
• Following the dishonor, respondent Yao personally delivered a demand letter to petitioner’s office, which was received by his secretary.

Criminal Charges and Trial Proceedings

• Petitioner was charged with four counts of violation of Batas Pambansa Blg. 22 for issuing checks without sufficient funds.
• The cases were raffled to Metropolitan Trial Court (MeTC), Branch 58, initially presided over by Judge Elvira D.C. Castro.
• Key proceedings and developments in the trial include:
• Petitioner’s plea of “not guilty” on September 16, 2004;
• The trial proceeded after mediation and pre-trial conferences under Judge Castro until her promotion led to Judge Marianito C. Santos taking over;
• On July 25, 2007, Judge Philip Labastida was appointed Presiding Judge of Branch 58, assuming trial proceedings; and
• Due to petitioner’s failure to present evidence, the case was submitted for decision with the promulgation set for September 30, 2008.
• The untimely death of Judge Labastida in December 2008 led to the designation of Judge Mary George T. Cajandab-Caldona as Acting Presiding Judge on February 20, 2009, effective April 1, 2009.

The MeTC Ruling

• On April 15, 2009, Judge Santos (as the pairing judge) rendered a decision finding petitioner guilty beyond reasonable doubt on four counts.
• The decision imposed penalties including:
• A fine of P200,000 per count;
• Subsidiary imprisonment not to exceed six months per count in case of insolvency; and
• Civil liability to pay the face value of the four dishonored checks aggregating P6,082,000.00, with an interest rate of 12% per annum from the date of extrajudicial demand until full payment.
• The MeTC based its conviction on:
• The fact that the checks represented payments for the loan; and
• The evidence that a demand was made to petitioner through his secretary after the dishonor of the checks.

RTC Proceedings and Further Developments

• Petitioner filed a petition for certiorari with the RTC questioning Judge Santos’ authority to promulgate the decision, claiming that his authority ceased upon the appointment of Judge Caldona as Acting Presiding Judge.
• On June 15, 2010, the RTC issued an Order upholding the conviction, ruling that the expanded authority of pairing judges under Circular No. 19-98 remained in force for cases submitted for decision before the formal assumption of the new presiding judge.
• Petitioner’s subsequent motion for reconsideration was denied by the RTC on December 28, 2010.

Procedural and Remedy Issues Raised by Petitioner

• Petitioner contended that the decision rendered by Judge Santos was invalid after Judge Caldona assumed office, arguing that the pairing judge’s authority automatically ceased at that point.
• He also challenged the sufficiency of proof regarding the service and receipt of the notice of dishonor.
• Petitioner further asserted that a petition for certiorari under Rule 65 was proper to redress acts of grave abuse of discretion by the lower court.

Issue:

Validity of the Decision Rendered by a Pairing Judge

• Whether a decision promulgated and executed by a pairing judge remains valid after the appointment and assumption to duty of a permanent (or acting presiding) judge.

Sufficiency of the Notice of Dishonor Requirement

• Whether the adjudication, which convicted the accused despite an alleged failure to prove the proper service and receipt of the notice of dishonor, constitutes grave abuse of discretion.

Appropriateness of the Remedy Sought

• Whether petition for certiorari under Rule 65 is the proper remedy to question acts allegedly amounting to grave abuse of discretion, particularly when an appeal was available and a prior motion for reconsideration was not filed.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)