G.R. No. 146921-22 - People vs. Flores

The case involves the issuance of a post-dated check, PCIB Check No. 558574, dated October 20, 1992, in the amount of P662,250.00.
The check was allegedly given by accused-appellant Mary Grace Carol Flores to Pacita G. Del Rosario in payment for a diamond ring—a 5-karat ring with a cluster of about 10 small diamonds—and an additional P250.00 claimed to be for transportation fare.
The check was issued despite the knowledge that the bank account had insufficient funds, as the accused’s account was closed on the same day the check was postdated.

Accused-appellant was charged with estafa, defined under Article 315, paragraph 2(d) of the Revised Penal Code, for issuing the check under false pretenses.
She was also charged with violation of Batas Pambansa Blg. 22 for making, drawing, and issuing the same check knowing at the time there were insufficient funds in her bank account.
The allegations emphasized that the accused, with fraudulent intent, misled the complainant by assuring that there were sufficient funds, which was later contradicted by the dishonor of the check.

Complainant Pacita del Rosario testified that on October 19, 1992, she sold the diamond ring to the accused and received the post-dated check as full payment.
She confirmed that upon depositing the check at a bank branch (Far East Bank in Greenhills, San Juan), the check was dishonored due to the account closure.
Bank employee Librado Manzano testified that the accused opened her account in September 1992 and closed it on October 20, 1992, with other checks from her account also being returned for insufficiency of funds.

The accused testified that the check was not a payment for a purchased ring but was issued as security for a P50,000.00 loan, with the excess P662,000.00 being purportedly for interest over a one-year period.
Her version of the transaction, however, revealed inconsistencies and improbabilities—such as the improbably high interest on a P50,000.00 loan—that cast doubt on her explanation.
The defense attempt to portray the transaction as a business investment in her drapery enterprise was undermined by her contradictory statements during cross-examination.

The Regional Trial Court found the accused guilty of both estafa and violation of B.P. Blg. 22, sentencing her to an indeterminate prison term of eight (8) years and one (1) day to ten (10) years for estafa and an additional term of one (1) year for the violation, together with a fine of P100,000.00.
The Court of Appeals affirmed the conviction but modified the sentence for estafa by imposing thirty (30) years of reclusion perpetua, basing the decision on the computed amount defrauded.
On appeal, the Supreme Court reviewed the case, especially the application of the Indeterminate Sentence Law in light of the increased penalty.

A warrant of arrest was issued on August 26, 1993, though the accused was not finally arrested until November 13, 1994.
The evidence also comprised two demand letters from the complainant, dated November 10, 1992, which the accused-appellant did not properly contest.
The case ultimately reached the Supreme Court following the controversy over the proper imposition and computation of the penalty under both the Revised Penal Code and the Indeterminate Sentence Law.

Whether Mary Grace Carol Flores committed estafa and violation of B.P. Blg. 22 by issuing a post-dated check without sufficient funds.

Whether the elements of estafa—specifically issuing a check as payment when the issuer knew there were insufficient funds—are present in this case.
Whether the accused’s contradictory testimonies regarding the purpose of the check (purchase of a ring versus a loan) affect the determination of fraudulent intent.

Whether the Indeterminate Sentence Law is properly applicable in this case, considering the sentencing shift from the trial court’s indeterminate term to the appellate court’s imposition of thirty (30) years of reclusion perpetua.

Whether the penalty computations under the Indeterminate Sentence Law, particularly the adjustment to a minimum term from prision mayor, are correctly applied.
Whether the characterization of the maximum penalty as reclusion perpetua is merely descriptive, and the law requires an application of the prescribed indeterminate sentence mechanics.