Case Digest (G.R. No. L-63419) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 230 Phil. 406, a consolidated petition filed on December 18, 1986, Florentina A. Lozano, Luzviminda F. Lobaton, Antonio Datuin and Susan Datuin, Oscar Violago, Elinor Abad, Amable R. Aguiluz VII and Sylvia V. Aguiluz, Luis M. Hojas, and finally the People of the Philippines challenged orders of various Regional Trial Courts and a Court of First Instance that denied their motions to quash criminal informations filed under Batas Pambansa Blg. 22 (the Bouncing Check Law). These petitioners had been charged with offenses arising from checks dishonored for insufficiency of funds. All trial courts but one (in G.R. No. 75789) upheld the law’s constitutionality and refused to quash the informations; in G.R. No. 75789 the judge declared BP 22 unconstitutional and dismissed the case. The Solicitor General opposed interlocutory elevation but the Supreme Court, recognizing the issue’s gravity, agreed to resolve the constitutional challenge under the 1973 Constitution.Issues:
- Is Bata
Case Digest (G.R. No. L-63419) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petitioners and Proceedings
- Multiple petitioners (G.R. Nos. 63419; 66839-42; 71654; 74524-25; 75122-49; 75812-13; 75765-67; 75789) challenged the constitutionality of Batas Pambansa Bilang 22 (BP 22), the “Bouncing Check Law.”
- Respondent trial courts denied motions to quash the criminal informations in all but one case (G.R. No. 75789), where the court declared BP 22 unconstitutional and dismissed the information.
- Nature of BP 22
- Enacted April 3, 1979, BP 22 punishes any person who “makes or draws and issues any check…knowing at the time of issue that he does not have sufficient funds…which check is subsequently dishonored…for insufficiency of funds.”
- Penalties: imprisonment from 30 days to 1 year, or fine not less than the amount of the check nor more than double, up to ₱200,000, or both; similar penalty for failure to maintain sufficient funds within 90 days of issuance.
- Threshold and Merits
- Although motions to quash are generally interlocutory, the Supreme Court admitted the petitions due to the paramount importance of resolving BP 22’s validity.
- The Court limited its review to the constitutionality of BP 22, without delving into the specific facts of each information.
Issues:
- Constitutional Validity
- Does BP 22 violate the constitutional prohibition against imprisonment for debt or non-payment of a poll tax (Art. IV, Sec. 13, 1973 Constitution)?
- Other Constitutional Objections
- Does BP 22 impair freedom of contract?
- Does it deny equal protection by penalizing only the drawer and not the payee?
- Does it unduly delegate legislative or executive power by making commission depend on the payee’s act of presentment?
- Was BP 22’s enactment procedurally flawed under Article VII, Section 9(2) (no amendments on Third Reading)?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)