Facts:

• The case involves Nissan Gallery-Ortigas (petitioner) and Purificacion F. Felipe (respondent).
• Purificacion's son, Frederick Felipe, purchased a Nissan Terrano 4x4 on May 14, 1997, for P1,020,000.00, structured as Cash-on-Delivery with no down payment.
• Frederick failed to pay upon delivery and used the vehicle for over four months without payment.
• Nissan sent two demand letters, which Frederick ignored.
• On November 25, 1997, Frederick asked Purificacion to issue a postdated check for the amount owed, which she did.
• The check was dishonored due to a "STOP PAYMENT" order.
• Nissan sent a demand letter to Purificacion, who refused to replace the check, asserting she was not the purchaser.
• On January 6, 1998, Nissan filed a criminal complaint against Purificacion for violating Batas Pambansa Blg. 22 (BP 22).
• Purificacion made a partial payment of P200,000.00 during the preliminary investigation but did not make further payments.
• The Metropolitan Trial Court (MeTC) acquitted her of the criminal charge but held her civilly liable for P675,000.00.
• Purificacion appealed to the Regional Trial Court (RTC), which affirmed the MeTC's decision.
• The Court of Appeals (CA) reversed the RTC's ruling, stating Purificacion had no privity of contract with Nissan and could not be held civilly liable due to her acquittal.
• Nissan filed a petition for review on certiorari to the Supreme Court.

Issue:

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Ruling:

• The Supreme Court ruled that Purificacion is civilly liable for the issuance of the worthless check despite ...(Unlock)

Ratio:

• The Court stated that a civil action is initiated with the filing of a criminal action, as per Section 1, Rule 111 of the Rules of Court.
• In violations of BP 22, the civil action is included with the criminal action, and separate filing is not allowed.
• Issuing a bad check is a violation of the law, regardless of intent.
• Pu...continue reading