G.R. No. 215118 - Mandagan vs. Jose M. Valero Corp.

JMV Corporation, acting as a private complainant, granted an accommodation to Maria Nympha Mandagan by allowing her to use its corporate name and account to secure a car loan for personal use.

The arrangement was supported by a lease-to-own agreement with BPI Leasing Corporation involving a 2001 Kia Rio sedan, wherein BPI remained the registered owner until full payment was made.

Mandagan issued thirty-four (34) postdated checks representing monthly amortization payments under the agreement.

Out of the 34 postdated checks, fourteen (14) were successfully deposited and honored, while eleven (11) checks were dishonored for reasons such as insufficient funds or a closed bank account.

JMV Corporation, upon learning of the dishonored checks, promptly notified Mandagan through its treasury head and general account supervisor, demanding payment or replacement of the faulty checks.

Mandagan initially promised to replace the dishonored checks and settle her outstanding obligations by making a one-time payment, but her assurances were not followed by compliance.

JMV Corporation pursued legal action by filing a criminal case for violation of B.P. 22 against Mandagan, charging her with eight counts based on the dishonored checks.

The Metropolitan Trial Court (MeTC) initially found Mandagan guilty on eight counts of violation of B.P. 22, relying partly on alleged admissions during preliminary conference proceedings and her counter-affidavit.

The evidence revolved around whether Mandagan had received the lawyer’s demand letter (notice of dishonor), which is necessary to impute the requisite knowledge of insufficiency of funds as required by law.

On December 28, 2009, the MeTC convicted Mandagan and imposed fines along with orders for payment covering the value of the dishonored checks plus interest.

Mandagan then appealed her conviction and, in the Decision dated February 15, 2011, the Regional Trial Court (RTC) reversed the MeTC’s criminal conviction, acquitting her on the ground that the prosecution failed to prove all elements of the offense; however, it retained the civil liability.

The RTC’s decision rested on the absence of clear, admissible evidence showing that Mandagan had received the written notice of dishonor, noting that the alleged admissions in the pre-trial conference and counter-affidavit were either unsigned or made post-filing of the complaint.

JMV Corporation, aggrieved by the RTC’s acquittal, filed a petition for certiorari with the Court of Appeals (CA) arguing that the RTC committed grave abuse of discretion.

The CA reversed the RTC’s decision in its ruling dated June 16, 2014, reinstating the MeTC’s conviction based on evidence including a Reply-Letter and an alleged admission over the phone regarding receipt of the demand letter.

A subsequent CA Resolution dated October 29, 2014 denied Mandagan’s motion for reconsideration, prompting her to file the present petition for certiorari before the Supreme Court.

Whether the Court of Appeals committed reversible error in annulling the Regional Trial Court’s Decision dated February 15, 2011 that acquitted petitioner Mandagan of the criminal charges.
Whether the evidence, particularly the alleged admissions and the Reply-Letter, is sufficient to establish that Mandagan received the written notice of dishonor required under B.P. 22.
Whether the use of the extraordinary remedy of certiorari to re-examine evidence and factual findings violates the constitutional rule against double jeopardy.