G.R. No. L-57555 - People vs. Jalandoni

Teresa L. Jalandoni maintained a current account with the Rizal Commercial Banking Corporation (RCBC, Greenhills Branch), assigned Account No. 6-06061.

Simultaneously, she (jointly with her late husband and later with her daughter, Ma. Theresa Macapagal) maintained a current account with the Bank of the Philippine Islands (BPI, Plaza Cervantes Branch), Account No. 2274-1.

The establishment of these accounts and the longstanding depositor relationships formed the basis for the bank extending overdraft (OD) or drawn against uncollected deposit (DAUD) privileges to her.

The information charged that between September 8 and September 10, 1976, Teresa Jalandoni, with intent to defraud, issued a series of personal checks totaling P2,150,000.00.

Of the nine (9) checks issued against her RCBC account, only one check (for P200,000.00) cleared while the remaining checks were dishonored due to insufficient funds.

Simultaneously, she deposited these RCBC checks into her BPI account, and before the RCBC checks could clear, she induced the BPI bank manager through false representations to honor additional checks drawn by her for a total amount of P2,041,780.00.

The deposits and withdrawals were conducted in a manner consistent with the practice of drawing against uncollected deposits, as evidenced by the bank statements and the use of checks marked with “JE” (Journal Entry).

Testimonies by bank officials, notably Manuel L. Garcia and Eriberto M. Ignacio, confirmed that the checks and subsequent overdrafts were posted following standard banking procedures, reflecting the account’s credit balance and overdraft computations.

Detailed exhibits (Exhibits 1 to 32 and others) were presented to illustrate the series of transactions, the issuance of checks, deposits made, and the resulting overdraft balances.

Although the transactions involving the checks and deposit endorsements were not disputed in their veracity by the appellant, she acknowledged issuing the nine checks and the resulting dishonor of eight of them due to insufficient funds.

The defense contended that the appellant had been granted overdraft privileges based on her longstanding relationship with the bank, thereby negating any presumption of fraudulent intent.

Additional evidence showed that the appellant took remedial actions by funding one check and reducing the overall damage to the bank (with the resultant damage computed at P1,391,780.00), including efforts such as mortgaging a lot (with her son’s authority) and delivering jewelry as tokens of sincerity to pay her obligations.

The testimony of Manuel L. Garcia, the branch manager at Plaza Cervantes when the transactions took place, confirmed that the checks were honored based on the appellant’s good credit standing and the bank's established practice of honoring checks drawn against uncollected deposits.

Subsequent testimony by Eriberto M. Ignacio, who succeeded Manager Garcia, further clarified the procedures in the bank’s accounting system, including how deposits, checks, and overdraft balances were recorded and computed.

The defense argued that if there had been any fraudulent scheme on the part of the appellant, the bank manager’s active cooperation would have been implicated, yet no such cooperation was shown.

Whether Teresa Jalandoni committed fraud by issuing checks under false pretenses, specifically by misrepresenting that the deposited RCBC checks were fully funded.
Whether the established practice of granting overdraft (OD) or drawn against uncollected deposit (DAUD) privileges to the appellant negates the element of fraudulent intent necessary for conviction under estafa.
Whether the manner in which the checks were drawn (i.e., in favor of third parties rather than for her own benefit) and the subsequent actions taken by the appellant (such as funding one of the checks and reducing the damage) are inconsistent with an intent to defraud.
Whether the evidentiary testimonies of BPI branch managers and the detailed bank statements sufficiently demonstrate that the appellant acted within the bank’s standard procedures.