Case Summary (G.R. No. 184203)
MeTC Findings and Judgment
The MeTC found the dishonor of the checks established by the “DAIF” endorsement and letters of dishonor received by petitioners. The court rejected the defense of payment for lack of documentary proof and ruled that petitioners, as drawers of the checks, knew of insufficient funds. It imposed fines of ₱200,000 per check, subsidiary imprisonment in case of insolvency, civil indemnity of ₱283,600, and costs.
RTC Affirmation
On appeal, the Regional Trial Court (RTC) of Manila upheld the MeTC decision, finding:
• Jurisdiction lay with MeTC Manila because the affidavit‐complaint alleged issuance of the checks in Manila.
• Presentation of original checks and proof of notice of dishonor satisfied the prosecution’s burden on dishonor and knowledge.
• Corporate officers are criminally liable under B.P. Blg. 22 for issuing checks, even as guarantees.
CA Decision
The Court of Appeals denied the petition for review, reiterating that:
• Venue for B.P. Blg. 22 may be at the place of issuance or payment of the check.
• Allegation in the affidavit‐complaint that the checks were issued in Manila vested MeTC with jurisdiction.
• The purpose of issuance or corporate status of the drawer does not negate criminal liability.
Issues on Supreme Court Review
Petitioners contended that:
- The MeTC lacked territorial jurisdiction because the allegation of issuance in Manila was hearsay and unproven.
- The CA erred in applying a presumption of knowledge of insufficient funds without proof.
- The prosecution failed to prove guilt beyond reasonable doubt.
Supreme Court Ruling on Territorial Jurisdiction
Focusing on the first issue, the Supreme Court held that territorial jurisdiction is an essential element that must be established by evidence, not mere allegation. It emphasized that in continuing or transitory crimes under B.P. Blg. 22, jurisdiction may be based on where the check was drawn, issued, delivered, presented, or dishonored—but such factual
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Facts
- On 16 August 2001, petitioners Raffy Brodeth and Rolan B. Onal were charged before the Metropolitan Trial Court (MeTC), Branch 30, Manila, with two counts of violating Batas Pambansa Blg. 22.
- Criminal Case No. 371104-CR: Metrobank Check No. 2700111416 (dated 5 September 1999) for ₱123,600.00, knowingly drawn against insufficient funds, dishonored “DAIF,” and unpaid within five banking days after notice.
- Criminal Case No. 371105-CR: Metrobank Check No. 2700111415 (dated 31 August 1999) for ₱140,000.00, similarly dishonored and unpaid.
- Private complainant Abraham G. Villegas, Operations Manager of Vill Integrated Transport Corp., alleged L & S Resources Phils., Inc. used company equipment, made partial payments by checks, but failed to settle outstanding balances.
- Two subject checks were dishonored; demand letters were sent on 9 October 1999 and 3 May 2000.
- Petitioners’ defense: Brodeth’s counter-affidavit (8 May 2008) claimed cash settlement and responsibility of Noli Dela Cerna; Onal’s letter (10 November 1999) echoed billing Cerna instead.
MeTC Ruling
- Found petitioners guilty beyond reasonable doubt for issuing bouncing checks.
- “DAIF” endorsement on checks constituted prima facie evidence of dishonor; petitioners admitted receipt of notices.
- Defense of payment failed: no receipts, unreliable claim of company closure, Exhibit “2” inadmissible photocopy, no specific reference to subject che