Case Summary (G.R. No. 155619)
Charge and Background
On August 20, 1992, Bayani issued Check No. 054924 in the amount of TEN THOUSAND PESOS (P10,000.00) drawn against Philippine Savings Bank (PS Bank), knowing that he had insufficient funds to cover the check. The check was eventually dishonored by the drawee bank, leading to a formal complaint by Dolores Evangelista, who was the payee of the check. Following a trial, the Regional Trial Court (RTC) of Lucena City convicted Bayani on November 20, 1995.
RTC Decision
The RTC found Bayani guilty of violating Batas Pambansa Blg. 22 and sentenced him to one year of imprisonment and a fine of P5,000. In addition, he was ordered to pay Evangelista the amount of P10,000, which represented the dishonored check, along with P5,000 for attorney’s fees, with double costs assigned to the respondent. The court’s decision was founded on solid evidence linking Bayani to the dishonored check and demonstrating a lack of sufficient funds at the time of issuance.
Factual Findings
The RTC highlighted that Bayani received a check booklet from PS Bank, which included the dishonored check. The check was post-dated and subsequently returned for insufficient funds. Evangelista attempted to resolve the matter through confrontations with Bayani and an intermediary, Alicia Rubia. Bayani offered only flat denials concerning any agreement about payment.
Appeal to the Court of Appeals
Upon appeal, the Court of Appeals (CA) affirmed the RTC's decision on January 30, 2002. The appellate court concluded that the circumstances surrounding the case did not illustrate any good faith or error on Bayani’s part, thus affirming his conviction with costs.
Grounds of Appeal
Bayani contended that the CA erred in refusing to acquit him on several grounds, including the claims that the conviction relied heavily on hearsay evidence, that the issuance of the check lacked proper consideration, and that the courts relied on presumptions rather than competent evidence.
Arguments by the Office of the Solicitor General
The Office of the Solicitor General (OSG), representing the respondent, countered that Bayani's denial did not negate the fact that his signature was on the check. They argued that lack of consideration was a personal defense and that the presumption of innocence was overcome by sufficient evidence.
Standards of Review
The Supreme Court established that the factual findings of the RTC and CA must be respected unless it is proven that there was a clear oversight in their assessment of evidence. The Court's jurisdiction was limited to legal errors, not to re-evaluate factual determinations already made by lower courts.
Ruling on Hearsay Evidence
Bayani contested Evangelista's testimony as being hearsay since it relied on statements from Rubia, who did not testify. Nonetheless, the Court ruled that Bayani had waived his right to object to the testimony by failing to raise the issue timely in the trial phase. Thus, even though hearsay, the testimony could still be considered, although its value might be limited.
Relevance of Evidence
The Court maintained that while Evangelista's testimony was hearsay, it served to establish the fact of her communication with Rubia regarding Bayani. However, the Court noted that this did not detract from the substantial evidence ag
...continue readingCase Syllabus (G.R. No. 155619)
Case Overview
- Parties Involved: Leodegario Bayani (Petitioner) vs. People of the Philippines (Respondent).
- Case Number: G.R. No. 155619.
- Date of Decision: August 14, 2007.
- Court: Supreme Court of the Philippines, Third Division.
Facts of the Case
- Leodegario Bayani was charged with a violation of Batas Pambansa Blg. 22 for issuing a check with insufficient funds.
- The check in question, Check No. 054924, dated August 26, 1992, was issued in the amount of ₱10,000.00 and drawn against the Philippine Savings Bank (PS Bank), Candelaria Branch.
- The check was given to Dolores Evangelista in exchange for cash.
- At the time of issuance, Bayani was aware that he did not have sufficient funds in his account; the check was later dishonored due to insufficient funds.
Trial Court's Decision
- The Regional Trial Court (RTC) of Lucena City, Branch 55, convicted Bayani on November 20, 1995.
- Sentences included:
- One year of imprisonment
- A fine of ₱5,000.00
- Payment of ₱10,000.00 to Evangelista
- Payment of ₱5,000.00 in attorney's fees and double costs of the suit.
Findings of the Trial Court
- The RTC established that:
- Bayani had received a check booklet from PS Bank, which included Check No. 054924.
- The check was post-dated and subsequently returned due to insufficient funds.
- Bayani's account was closed shortly after the check was issued.
Court of Appeals' Ruling
- The Court of Appeals (CA) affirmed the RTC’s decision on January 30, 2002, supporting the trial court