Case Digest (G.R. No. 96132)
Facts:
Oriel Magno v. Honorable Court of Appeals and People of the Philippines, G.R. No. 96132, June 26, 1992, Second Division, Paras, J., writing for the Court.Petitioner Oriel Magno sought to establish a car repair shop in April 1983 but lacked equipment and funds. Representing Ultra Sources International Corporation, he approached Corazon Teng, Vice-President of Mancor Industries (the supplier), who referred him to LS Finance and Management Corporation (“LS Finance”) and its vice-president, Joey Gomez, to obtain credit for lease-purchase of garage equipment. Under the leasing arrangement, the lessee was to post a “warranty deposit” equal to 30% of equipment value (P29,790.00) as security; petitioner did not have this amount and asked Gomez to find a third party to advance it.
Unknown to petitioner, Mrs. Teng advanced the warranty deposit as a short-term loan at 3% interest. After equipment delivery, petitioner issued postdated checks to Gomez who forwarded them to Teng. Petitioner later issued six postdated checks to replace an earlier one; two cleared but four remained with Teng and were later presented and dishonored with the bank’s remark “account closed.” The four dishonored checks formed the four criminal counts charging violations of Batas Pambansa Blg. 22 (anti–dishonored checks statute).
After joint trial, the Regional Trial Court, Branch 104, Quezon City, convicted petitioner of violations of BP Blg. 22 on the four counts and imposed penalties and payment orders. The Court of Appeals (in CA-G.R. CR No. 04889) affirmed the conviction in toto. Petitioner brought a petition for review by certiorari under Rule 45 to the Supreme Court, contending inter alia that the checks were issu...(Pro-only)
Issues:
- Did the trial court and the Court of Appeals err in convicting petitioner of violations of BP Blg. 22 when the prosecution failed to prove beyond reasonable doubt that the checks were issued “on account or for value” and that petitioner knew he lacked sufficient funds?
- Did the Court of Appeals improperly shift the burden to petitioner to prove that the underlying obligation had been extinguished, contrary to the presumption of innocence...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)