Case Digest (G.R. No. 129764)
Case Digest (G.R. No. 129764)
Facts:
Griffith v. Court of Appeals, G.R. No. 129764, March 12, 2002, Supreme Court Second Division, Quisumbing, J., writing for the Court. Petitioner is Geoffrey F. Griffith, sued in his capacity as president of Lincoln Gerard, Inc.; private respondent is Phelps Dodge Philippines, Inc.; respondents in the procedural posture include the Court of Appeals, the Regional Trial Court (RTC), and the Metropolitan Trial Court (MeTC) judges who handled the case below.In 1985 Phelps Dodge leased premises to Lincoln Gerard; Lincoln Gerard fell into rental arrears. In 1986 Griffith, as president, issued two corporate checks to Phelps Dodge (dated April 15, 1986 for P100,000.00 and May 1, 1986 for P115,442.65). Attached vouchers bore instructions that the checks were not to be presented without Lincoln Gerard’s prior approval to be given not later than May 30, 1986, and a Phelps Dodge note that absence of such approval would authorize presentation. Griffith notified Phelps Dodge on May 29 that the checks could not be funded because of a four‑week labor strike.
Phelps Dodge nevertheless presented the checks on June 2, 1986; they were dishonored for insufficiency of funds. Phelps Dodge demanded payment and, on June 20, 1986, conducted a notarial foreclosure and auction of Lincoln Gerard’s impounded properties to satisfy the arrearages. Two years later, on May 10, 1988, informations for violation of Batas Pambansa Blg. 22 (B.P. 22) were filed against Griffith in the RTC (Criminal Cases Nos. 73260 and 73261). A motion to quash, a DOJ review and other remedies were unsuccessful; the cases were remanded to the MeTC after expansion of its jurisdiction under R.A. No. 7691.
Separately, on November 6, 1987 Lincoln Gerard filed Civil Case No. 55276 against Phelps Dodge in RTC Branch 69 (Pasig). On July 19, 1991 that RTC declared the foreclosure and auction invalid, applied proceeds against arrears and ordered return of P1,072,586.88 as excess; the Court of Appeals affirmed that ruling, which became final and executory. Meanwhile, on July 25, 1995 the MeTC convicted Griffith of two counts of B.P. 22 and sentenced him to six months’ imprisonment per count (to be served consecutively); the RTC affirmed. The Court of Appeals, in CA‑G.R. SP No. 19621, denied petition for review and later denied reconsideration (March 14, 1997 decision; July 8, 1997 resolution). Petitioner then elevated the matter to the Supreme Court by petition seeking reversal of the Court of Appeals’ decision.
Issues:
- Is the constitutional challenge to the application of B.P. 22 appropriate for resolution in this case?
- Did Phelps Dodge’s collection of the value of the checks through foreclosure and auction (and the circumstances surrounding that collection) bar or render unjust petitioner Griffith’s criminal conviction under B.P. 22?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)