Case Digest (G.R. No. 164358)
Facts:
- Theresa Macalalag borrowed two loans of P100,000.00 each from Grace Estrella on July 30, 1995, and October 16, 1995, with a 10% monthly interest rate.
- Macalalag made regular interest payments until she found the rates burdensome and requested a reduction.
- Estrella agreed to a reduced interest rate of 6% per month, and Macalalag executed Acknowledgment/Affirmation Receipts on April 16, 1996, and May 1, 1996, promising to pay the total loan amount of P200,000.00 within two months.
- Macalalag also agreed to pay P100,000.00 as liquidated damages and P40,000.00 as attorney's fees in case of breach.
- To secure the loans, she issued two checks (Check No. C-889835 and No. 889836) for P100,000.00 each on June 30, 1996.
- The checks were dishonored due to a closed account, and Estrella sent a notice of dishonor to Macalalag.
- Estrella filed two criminal complaints for violation of Batas Pambansa Blg. 22, leading to Criminal Cases No. 76367 and No. 76368.
- Macalalag pleaded "not guilty" but admitted her debt and the issuance of the checks during the trial.
- She claimed to have paid P355,837.98, which Estrella contended was applied to interest.
- On February 5, 2001, the MTCC found Macalalag guilty, imposing a fine of P100,000.00 for each check and civil indemnity of P200,000.00.
- The RTC affirmed the MTCC's decision, and the Court of Appeals modified the ruling, convicting her of one count related to the second check only.
Issue:
- (Unlock)
Ruling:
- The Court affirmed Macalalag's liability for one count of violation of Batas Pambansa Blg. 22 concerning the dishonor of the second check.
- The Court ruled that the stipulated interest rates were unconscionable and reduced them to 12% per annum.
- The Court held that payments mad...(Unlock)
Ratio:
- The Supreme Court emphasized that the elements of violation of Batas Pambansa Blg. 22 were present: issuance of checks, knowledge of insufficient funds, and subsequent dishonor.
- The law is strict regarding checks issued without sufficient funds, and lack of criminal intent is irrelevant.
- The Court recogn...continue reading
Case Digest (G.R. No. 164358)
Facts:
The case involves Theresa Macalalag as the petitioner and the People of the Philippines as the respondent. The events leading to this case began when Macalalag obtained two loans from Grace Estrella, each amounting to P100,000.00, on July 30, 1995, and October 16, 1995, respectively, with an interest rate of 10% per month. Macalalag made consistent interest payments starting August 30, 1995, but later found the interest rates burdensome and requested a reduction. Estrella agreed, and on April 16, 1996, and May 1, 1996, Macalalag executed Acknowledgment/Affirmation Receipts, promising to pay the total loan amount of P200,000.00 within two months at a reduced interest rate of 6% per month. Additionally, she agreed to pay P100,000.00 as liquidated damages and P40,000.00 as attorney's fees in case of breach.
To secure the loans, Macalalag issued two checks (Check No. C-889835 and No. 889836) on June 30, 1996, each for P100,000.00. However, when Estrella presented these checks for payment, they were dishonored due to a closed account. Estrella sent a notice of dishonor to Macalalag, who failed to make good on the checks. Consequently, Estrella filed two criminal complaints for violation of Batas Pambansa Blg. 22 before the Municipal Trial Court in Cities (MTCC) of Bacolod City, which were docketed as Criminal Cases No. 76367 and No. 76368. Macalalag pleaded "not guilty" during her arraignment.
During the trial, Macalalag admitted her indebtedness and the issuance of the checks but claimed to have paid a total of P355,837.98, including P199,837.98 during the pendency of the cases. Estrella acknowledged the payment but contended it was applied to interest. On February 5, 2001, the MTCC fo...