Facts:

• James Svendsen was found guilty of violating Batas Pambansa Blg. 22 (B.P. Blg. 22), the Bouncing Checks Law.
• In October 1997, Cristina Reyes extended a loan of PHP 200,000 to Svendsen at an interest rate of 10% per month.
• Svendsen partially paid his debt but failed to settle the remaining balance, which had grown to PHP 380,000 with interest.
• Svendsen paid PHP 200,000 and issued a postdated check for PHP 160,000, co-signed by Wilhelm Bolton, to cover the interest.
• The check, presented on February 9, 1999, was dishonored due to insufficient funds.
• Cristina Reyes sent a notice of dishonor by registered mail, demanding payment within five days.
• Svendsen did not pay, leading Cristina to file a complaint on March 1, 1999, for violation of B.P. Blg. 22.
• The Metropolitan Trial Court (MeTC) of Manila found Svendsen guilty, imposing a fine and civil indemnity of PHP 160,000 each.
• The RTC and Court of Appeals upheld the decision; Svendsen then petitioned the Supreme Court for review.

Issue:

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Ruling:

• The Supreme Court reversed the Court of Appeals' decision.
• James Svendsen was acquitted due to the prosecution's failure to establish guilt beyond a reasonable doubt.
• Svendsen was ordered to pay Cristina Reyes PHP 16,000 as civil indemnity, plus 12% interest per annum from April 29, 1...(Unlock)

Ratio:

• The prosecution did not prove that Svendsen received the required written notice of dishonor.
• The registry receipt did not sufficiently show that Svendsen or his agent received the notice.
• Penal statutes are interpreted strictly against the state and liberally in favor of the accused.
• Without proof of receipt, the presumption of knowledge of insufficient funds could not apply, leading to Svendsen's acquittal.
• Svendsen was st...continue reading