Case Digest (G.R. No. L-63419)
Facts:
Multiple petitioners, including Florentina A. Lozano, Luzviminda F. Lobaton, Antonio and Susan Datuin, and others, sought review of prosecutions under Batas Pambansa Bilang 22 (BP 22) before the Court en banc; the petitions were filed after trial courts largely denied motions to quash informations alleging BP 22 was unconstitutional, while in G.R. No. 75789 a trial court declared the law unconstitutional and dismissed the case. The Solicitor General argued the appeals were premature, but the Court, noting the importance of the issue, entertained the petitions and consolidated consideration of the constitutionality of BP 22.
Issues:
- Does BP 22 infringe the constitutional prohibition against imprisonment for debt (Section 13, Article IV, 1973 Constitution)?
- Does BP 22 impair the freedom of contract protected by the Constitution?
- Does BP 22 violate the equal protection clause by penalizing the drawer but not the payee?
- Does BP 22 effect an undue delegation of legislative or executive power by making commission of the offense depend on presentment by the payee?
- Was the enactment of BP 22 procedurally defective for violating the prohibition on amendments on Third Reading (Section 9(2), Article VII, 1973 Constitution)?
Ruling:
The Court upheld the constitutionality of BP 22 and dismissed the consolidated petitions except G.R. No. 75789, in which the Court granted the petition and set aside the trial court's order declaring the law unconstitutional; the temporary restraining order in G.R. Nos. 74524-25 was lifted and costs were awarded against the private petitioners. The Court held that the statute is a valid exercise of legislative power and does not contravene the cited constitutional provisions.
Ratio:
The Court reasoned that the gravamen of BP 22 is the making and issuance of a worthless check — an act malum prohibitum — and not mere nonpayment of a debt, so the statute does not amount to imprisonment for debt; rather, it is a legitimate exercise of the State's police power to protect public order and the integrity of the banking and commercial system. The statute's evidentiary presumptions are prima facie and rebuttable, and the Court found no unconstitutional impairment of contract, denial of equal protection, undue delegation of power, or fatal procedural defect in its legislative enactment.
Doctrine:
- BP 22 is a valid exercise of the State's police power to punish the issuance of worthless checks as an offense against public order, not imprisonment for debt.
- (Get Pro to unlock 4 more doctrines)