Case Digest (G.R. No. 198543) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Cecilio S. de Villa vs. Hon. Court of Appeals, People of the Philippines, Hon. Job B. Madayag, and Roberto Z. Lorayes (G.R. No. 87416, decided April 8, 1991), petitioner Cecilio S. de Villa was charged on October 5, 1987 before the Regional Trial Court (RTC) of Makati, Branch 145, with violating Batas Pambansa Blg. 22 (the Bouncing Checks Law). The Information alleged that on April 3, 1987, in Makati, Metro Manila, petitioner willfully issued Check No. 3371 drawn on his U.S. dollar account with Depositors Trust Company, payable to private respondent Roberto Z. Lorayez in the equivalent of ₱50,000.00, fully knowing that he had insufficient funds. Upon presentment within ninety days, the check was dishonored for “insufficient funds,” and petitioner failed to make payment within five banking days after notice. During trial, petitioner moved to dismiss on the grounds that the RTC lacked jurisdiction because the check was drawn on a foreign dollar account and that the obligation w Case Digest (G.R. No. 198543) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Criminal Information and Charge
- On October 5, 1987, petitioner Cecilio S. de Villa was charged before the Regional Trial Court, Makati, Branch 145, with violation of Batas Pambansa Blg. 22 for issuing Depositors Trust Company Check No. 3371 antedated March 31, 1987, payable to Roberto Z. Lorayez in the amount of US$2,500.00 (₱50,000.00), knowing he had insufficient funds; the check was dishonored within ninety days and petitioner failed to pay or arrange payment within five banking days after notice of dishonor.
- After arraignment and direct testimony of private respondent, petitioner moved to dismiss the Information, arguing (a) lack of jurisdiction over a foreign‐currency check and (b) nullity of obligation under Republic Act No. 529 (prohibiting foreign currency obligations).
- Trial Court Proceedings
- On July 19, 1988, the RTC denied the motion to dismiss, holding that BP 22 covers foreign‐currency checks drawn or dishonored in the Philippines, including dollar accounts.
- On September 6, 1988, the RTC denied petitioner’s motion for reconsideration, reaffirming that BP 22 applies to checks drawn against current accounts in foreign currency.
- Court of Appeals Petition
- Petitioner filed a petition for certiorari in the Court of Appeals seeking to nullify the July 19 and September 6, 1988 orders, contending lack of jurisdiction and invalidity of dollar‐denominated obligation.
- On February 1, 1989, the Court of Appeals dismissed the petition; its March 3, 1989 resolution denied reconsideration.
- Supreme Court Review
- Petitioner filed this petition for review on certiorari; on November 13, 1989, the Supreme Court gave due course and required memoranda.
- The sole issue framed: whether the RTC of Makati has jurisdiction over the case involving a dollar‐denominated bounced check.
Issues:
- Jurisdiction
- Does the Regional Trial Court of Makati have jurisdiction over the criminal case for issuance of a dollar‐denominated check alleged to have bounced?
- Coverage of BP 22 and RA 529
- Does Batas Pambansa Blg. 22 apply to checks drawn against foreign‐currency accounts?
- Is the obligation created by a dollar‐denominated check null and void under Republic Act No. 529?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)