Case Digest (G.R. No. 242900) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Saulo v. People of the Philippines and Marsene Alberto, petitioner Edwin L. Saulo was the owner and president of Yadoo Dynasty and Khumbmela Products, Inc., while private respondent Marsene Alberto served as Disbursing Officer and later Operations Manager from 1992 to 1996. In October–November 1996, Saulo borrowed funds from Alberto and her associates and issued two corporate BDO checks (Nos. 0000157580 for ₱12,270 and 0000157581 for ₱29,300) drawn on Khumbmela’s account. Both checks bounced for “Account Closed” and “Insufficient Funds.” On December 17, 1996, Alberto sent him a Notice of Dishonor, which he received the same day. Instead of settling the indebtedness, Saulo filed complaints for estafa, qualified theft, and falsification against her; these were dismissed at the City Prosecutor’s office for lack of evidence. Thereafter, Alberto charged Saulo with two counts of Violation of Batas Pambansa Blg. 22 and one count of Perjury before the Metropolitan Trial Court (MeTC) Case Digest (G.R. No. 242900) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedent Facts
- Edwin L. Saulo (petitioner) owned Yadoo Dynasty and Khumbmela Products, Inc., manufacturing bags and accessories. He employed Marsene T. Alberto (private respondent) from 1992 to 1996 as Disbursing Officer, later Operations Manager. Facing financial problems, Saulo asked Alberto to help secure loans.
- Through Alberto’s connections:
- Saulo borrowed ₱1,500,000 from Eladio Naval, issuing three post-dated checks (₱1,200,000; ₱200,000; ₱100,000).
- In October 1996, Saulo borrowed ₱12,270 from Alberto, issuing BDO Check No. 0000157580 (Oct. 28, 1996).
- In November 1996, for studio construction, Alberto’s husband paid Masinag Lumber and Saulo issued BDO Check No. 0000157581 (₱29,300, Nov. 20, 1996).
- Both BDO checks were dishonored for “Account Closed” and “Insufficient Funds.” Alberto sent a Notice of Dishonor (Dec. 17, 1996), received same day.
- Versions of Parties
- Prosecution’s Version
- Alberto loaned Saulo the amounts; Saulo issued the checks drawn on Khumbmela’s account.
- After dishonor, Saulo filed estafa, qualified theft, and falsification complaints against Alberto, all dismissed. Alberto then filed perjury and two counts of B.P. 22.
- Defense’s Version
- Saulo denied issuing the contested checks, claimed no loan or business relationship with Alberto or Masinag Lumber.
- An internal audit (destroyed by Typhoon Ondoy) allegedly showed missing checks; Alberto disappeared thereafter. Saulo closed corporate accounts and filed qualified theft.
- Procedural History
- MeTC, Pasig City (Apr. 27, 2015):
- Convicted Saulo of two counts Violation of B.P. 22 and Perjury.
- Imposed fines and imprisonment; ordered ₱41,570 indemnity with 6% interest.
- RTC, Pasig City, Branch 268 (Dec. 22, 2015; order Sept. 26, 2016):
- Affirmed MeTC Decision and denied reconsideration.
- CA (May 23, 2018; resolution Oct. 19, 2018):
- Denied petition for review; affirmed RTC Decision and Order.
- SC: Petition for Review on Certiorari under Rule 45 filed by Saulo.
Issues:
- Whether Saulo willfully and deliberately asserted falsehood in his complaint-affidavit, constituting perjury under Article 183, RPC.
- Whether Saulo is criminally liable for Violation of B.P. 22 for issuance of dishonored corporate checks.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)