G.R. No. 211564 - Evangelista vs. Screenex, Inc.

In 1991, petitioner Benjamin Evangelista obtained a loan from Screenex, Inc., evidenced by two checks: UCPB Check No. 275345 for ₱1,000,000.00 and China Banking Corporation Check No. BDO 8159110 for ₱500,000.00. Vouchers signed by Evangelista acknowledged receipt of the loan proceeds.
As security, Evangelista issued two open-dated checks in favor of Screenex, Inc.: UCPB Check Nos. 616656 and 616657. These instruments were kept by Philip Gotuaco, Sr. (respondent Alexander Yu’s father-in-law) until Gotuaco’s death on November 19, 2004.

Prior to any deposit, Evangelista’s family and lawyer sent demand communications for settlement of the loan.
On August 25, 2005, Evangelista was charged before the Makati MTCC Branch 61 with two counts of violation of BP 22 for issuing checks dated December 22, 2004, knowing there were insufficient funds, and for failing to pay within five banking days after notice of dishonor.

The MTCC acquitted Evangelista criminally for failure to prove knowledge of insufficiency of funds but held him civilly liable for ₱1,500,000.00 plus 12% interest, ordering payment of costs.
On appeal, the RTC Branch 147 and thereafter the CA Fifth Division affirmed the civil liability, rejecting defenses of payment, alteration, witness incompetence, and prescription. Evangelista’s motions for reconsideration were denied, prompting this petition for review on certiorari.

Whether Evangelista remains civilly liable for the amounts indicated on the dishonored checks despite his criminal acquittal under BP 22.

Whether the action to enforce the civil obligation arising from undated checks is barred by the ten-year prescriptive period under Article 1144 of the Civil Code and the Negotiable Instruments Law.