G.R. No. 168203 - National Electrification Administration vs. Villanueva

Petitioner Vicky C. Ty was charged with seven (7) counts of violating Batas Pambansa Blg. 22 (B.P. 22 or the Bouncing Checks Law) before the Regional Trial Court (RTC) of Manila, Branch 19. The cases were docketed as Criminal Cases No. 93-130459 to No. 93-130465.
The allegations involved Ty issuing seven postdated checks, each amounting to P30,000.00, payable to Manila Doctors’ Hospital, which were subsequently dishonored by the drawee bank due to an “Account Closed” status.
Ty was accused of knowingly issuing checks without sufficient funds or credit and failing to pay or make arrangements for payment within five banking days after receiving notices of dishonor.

Ty’s mother, Chua Lao So Un, was hospitalized at Manila Doctors’ Hospital from October 30, 1990, to June 4, 1992, incurring hospital bills totaling P657,182.40.
Ty signed an “Acknowledgment of Responsibility for Payment” on behalf of her mother upon admission.
Ty’s sister, Judy Chua, was also confined at the hospital, incurring additional hospital bills of P418,410.55.
The total hospital bills from both patients amounted to P1,075,592.95.
On June 5, 1992, Ty executed a promissory note assuming responsibility for the hospital obligations and issued several postdated checks as security for payment.

The seven postdated checks, each for P30,000.00, were deposited by the hospital on respective due dates but were all dishonored due to insufficient funds.
Despite demand letters sent by registered mail, Ty failed to pay or settle the amounts.
Ty pleaded not guilty and admitted issuing the checks but claimed issuance was under an uncontrollable fear of greater injury, forced by the hospital’s inhumane treatment and conditional discharge demands.

Ty alleged the hospital subjected her mother to degrading treatment, including deprivation of room facilities, suspension of medical services, and improper care.
Fearful for her mother’s wellbeing and potential suicide, Ty claimed coercion to issue checks and open a bank account as conditions for discharge.
She disputed the existence of valuable consideration and asserted that the hospital knew of insufficient funds in her account.

The RTC found Ty guilty of seven counts of violation of B.P. 22, sentencing her to six months imprisonment per count (total 42 months).
Upon appeal, the Court of Appeals affirmed guilt but modified the penalty, imposing a fine equivalent to double the amount of each check (P60,000.00 per check), eliminating imprisonment.
The courts rejected defenses of involuntariness, absence of valuable consideration, and knowledge of the payee regarding insufficient funds, emphasizing that B.P. 22 penalizes the mere issuance of worthless checks.

Ty filed a Petition for Review under Rule 45, reiterating all prior defenses including coercion, lack of consideration, hospital’s knowledge of insufficient funds, and alleged injustice from mechanical application of B.P. 22.
The Office of the Solicitor General argued that the mere issuance of bouncing checks constitutes the offense regardless of circumstances or payee’s knowledge.
The Supreme Court reviewed the case based on these contentions.

Whether the defense of uncontrollable fear or coercion excuses petitioner’s criminal liability for issuing bouncing checks under B.P. 22.
Whether the absence of valuable consideration invalidates the prosecution for bouncing checks.
Whether knowledge of the payee (Manila Doctors’ Hospital) of insufficient funds in petitioner’s bank account excuses or negates petitioner’s criminal liability.
Whether the penalty of imprisonment imposed by the trial court should be modified or removed in light of administrative circulars and jurisprudence.
Whether the application of B.P. 22 in this case was appropriate or should be mitigated based on the circumstances raised by the petitioner.