G.R. No. 183399 - Ortiz vs. DHL Philippines Corp.

Background of Petitioners and Business Relationship
Petitioners Eduardo R. Vaca (president and owner) and Fernando Nieto (purchasing manager) of Ervine International, Inc., a refrigeration‐equipment manufacturer.
On March 10, 1988, they issued a ₱10,000 check to GARDS for security services, drawn on China Banking Corporation; it was dishonored for insufficiency at PCIBank.

Notices and Subsequent Check Issuance
On March 29, 1988, GARDS demanded payment in cash within seven days; petitioners did not comply.
On April 13, 1988, petitioners issued a ₱19,860.16 check on Associated Bank, stating it was to replace the dishonored check and cover additional charges; GARDS received it on April 15, 1988.

Procedural History
GARDS filed a complaint on April 14, 1988; the RTC (Branch 97) dismissed the first case on May 11, 1989, citing payment.
A second complaint filed September 18, 1989 led to an information in RTC Branch 100; the trial court convicted petitioners, the Court of Appeals affirmed on October 25, 1996 (resolution December 2, 1997), and petitioners elevated the case to the Supreme Court.

Whether the prosecution proved petitioners’ guilt beyond reasonable doubt under B.P. Blg. 22.
Whether the conviction improperly relied on the weakness of defense evidence rather than the strength of the prosecution’s evidence.
Whether petitioners are entitled to acquittal based on mistake of fact or lack of knowledge of insufficient funds.
Whether a post-conviction affidavit of desistance by GARDS’ president negates criminal liability.
Whether the penalty should be modified by deleting imprisonment in favor of an increased fine.