Facts:

The case involves Lina Lim Lao as the petitioner against the Court of Appeals and the People of the Philippines as respondents. The events leading to this case began in 1983 when Lina Lim Lao was employed as a junior officer at Premiere Investment House, specifically at its Binondo Branch. In her capacity, she was authorized to sign checks on behalf of the corporation. During her tenure, she interacted with Father Artelijo Pelijo, the provincial treasurer of the Society of the Divine Word, who had invested a total of P514,484.04 with Premiere. The checks issued to Father Pelijo, which were co-signed by Lao and her superior, Teodulo Asprec, were later presented for encashment but were dishonored due to insufficient funds. Following this, Father Pelijo made several demands for payment, which were unfulfilled, leading him to file an affidavit-complaint against Lao and Asprec for violating Batas Pambansa Bilang 22 (B.P. 22) on January 24, 1984.

The Regional Trial Court (RTC) o...

Facts:

Background and Roles:
Petitioner Lina Lim Lao was a junior officer at Premiere Investment House’s Binondo Branch. Her duties included signing blank corporate checks, which were later filled out by her superior, Teodulo Asprec, as to the payee, amount, and date.

The Transaction:
Complainant Father Artelijo Palijo invested P514,484.04 with Premiere. In July 1983, Premiere issued three checks to Father Palijo, co-signed by Lao and Asprec. The checks were subsequently dishonored for insufficient funds.

Prosecution’s Version:
The checks issued to Father Palijo were dishonored due to insufficient funds. Father Palijo demanded payment from Premiere, but only received P5,000. Premiere was later placed under receivership. Criminal charges were filed against Lao and Asprec for violating Batas Pambansa Bilang 22 (B.P. 22).

Defense’s Version:
Lao claimed she signed the checks in blank as part of her regular duties and had no knowledge of the insufficiency of funds. She argued that the Treasury Department, headed by Veronilyn Ocampo, was responsible for funding the checks. Lao also contended that she did not receive any notice of dishonor, as the notice was sent to Premiere’s main office, not her branch.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Knowledge of Insufficiency of Funds:

   • Under B.P. 22, a prima facie presumption of knowledge of insufficient funds arises from the dishonor of a check. However, this presumption can be rebutted.
   • Lao’s duties did not include monitoring the corporate account’s funds, and she had no actual knowledge of the insufficiency at the time of issuance.

2. Notice of Dishonor:

   • Section 2 of B.P. 22 requires that the maker or drawer of the check receive notice of dishonor to be afforded the opportunity to pay or arrange payment within five banking days.
   • Since no notice of dishonor was personally sent to Lao, the prima facie presumption of knowledge of insufficiency could not apply.

3. Strict Interpretation of Penal Laws:

   • Penal statutes must be strictly construed, and all elements of the offense, including knowledge and notice, must be proven beyond reasonable doubt.

4. Social Justice Considerations:

   • The Court emphasized that Lao, a junior employee, should not bear the brunt of criminal liability for corporate mismanagement, especially when the senior official (Asprec) remained at large.

The Supreme Court reversed the decision of the Court of Appeals and acquitted Lina Lim Lao, emphasizing the importance of protecting constitutional rights in criminal prosecutions.