G.R. No. 175188 - Commissioner of Internal Revenue vs. La Tondena Distillers, Inc.

Nissan Gallery-Ortigas, an automobile dealership, initiated a criminal complaint for violation of Batas Pambansa Blg. 22 (BP 22) against Purificacion F. Felipe.
The complaint stemmed from the issuance of a postdated check by Purificacion, which was later dishonored due to a stop-payment order.
The check was purportedly issued to settle an outstanding obligation of Frederick Felipe, Purificacion’s son, arising from his purchase of a Nissan Terrano 4x4 SUV.

Frederick purchased the vehicle at a significant discount, with the payment terms being Cash-on-Delivery and no downpayment required.
Despite taking possession and enjoying the use of the SUV for more than four months, Frederick failed to pay the full purchase price.
Nissan made repeated attempts to secure payment by sending two demand letters, and eventually a final demand letter, which led Frederick to seek a grace period and negotiate a reduced amount.

On November 25, 1997, Frederick requested his mother, Purificacion, to issue a postdated check for his unpaid obligation after negotiations reduced the amount to P1,020,000.00.
Purificacion acceded to the request and issued the check as payment for Frederick’s outstanding amount.
The check was subsequently dishonored upon presentment due to a stop-payment directive, prompting Nissan to serve a demand letter to Purificacion.

On January 6, 1998, Nissan filed a criminal case for violation of BP 22 against Purificacion F. Felipe.
During the preliminary investigation, Purificacion made a partial payment of P200,000.00 to settle the civil aspect; however, no further payments were rendered.
The Metropolitan Trial Court (MeTC) acquitted Purificacion of the criminal charge but held her civilly liable, ordering her to pay P675,000.00 with legal interest from the filing date until satisfaction of the judgment.
The Regional Trial Court (RTC), Branch 105, later affirmed the MeTC decision, characterizing Purificacion as an accommodation party liable on the instrument even if her role was that of merely boosting her son’s credit standing.

Purificacion appealed to the RTC, which maintained her civil liability despite her acquittal on the criminal charge due to the issuance of the check.
The Court of Appeals (CA) reversed the lower courts’ decisions by emphasizing the lack of privity between Nissan and Purificacion and her subsequent acquittal in the criminal proceeding, thereby arguing that she was not liable civilly beyond the mere fact of issuing the check.
Nissan moved for reconsideration, but the CA’s reversal remained, prompting the present petition for review on certiorari under Rule 45.

Whether the act of issuing a worthless check, which led to its dishonor, gives rise to civil liability even if the accused was acquitted of the criminal charge on grounds of insufficient proof of notice of dishonor.
Whether Purificacion’s role as an accommodation party (or otherwise) and her subsequent acquittal in the criminal case can fully exonerate her from the corresponding civil liability.

Whether the issuance of a postdated check (later dishonored due to a stop-payment) constitutes sufficient basis for civil liability under BP 22 despite the accused’s acquittal in the criminal proceedings.

Does the mere act of issuing a worthless check, regardless of the intent or the presence of privity, impose civil liability?
Can Purificacion’s claim that she acted merely as an accommodation party to boost her son’s credit standing absolve her of civil liability when the check was used to settle an outstanding obligation?

Whether an acquittal in the criminal case, based on the failure to prove the element of notice of dishonor, should automatically negate the civil liability derived from the same act or omission.

Is the double standard of proof (beyond reasonable doubt in criminal cases versus the preponderance of evidence in civil cases) sufficient to maintain a civil liability even after criminal acquittal?
Should the fact of issuing the check, as proven by lower courts, be deemed sufficient to impose civil liability independent of the criminal proceedings?