G.R. No. 217682 - Estrada vs. Sandiganbayan, 5th Division

Case Summary (G.R. No. 217682)

METC Ruling: Acquittal on Criminal Charge; Civil Liability Imposed

The METC acquitted petitioner of B.P. 22 on the ground of reasonable doubt because the prosecution failed to prove beyond reasonable doubt that petitioner knew of the insufficiency of funds—specifically, the prosecution failed to authenticate the registry return receipt to show actual receipt of the notice of dishonor. Nonetheless, the METC imposed civil liability on petitioner for the face value of the check (P436,800.00) with legal interest at 6% per annum from last demand (November 3, 2006), attorney’s fees (P30,000.00 plus P2,000.00 per court appearance), and costs.

RTC Ruling: Affirmance with Modification on Interest and Reckoning Date

On appeal, the RTC affirmed the METC’s acquittal but modified the civil award: it applied 12% per annum legal interest (relying on Eastern Shipping Lines as involving forbearance of credits) reckoned from judicial demand (filing of the Information on October 3, 2007) until full payment, and retained the award of attorney’s fees and costs. The RTC rejected petitioner’s contention that the debt was strictly corporate (RB Freight’s) and that he could not be personally liable, holding that he personally signed the check and B.P. 22 punishes issuance of a bouncing check regardless of the purpose.

CA Ruling: Affirmed RTC; Applied Nacar Interest Formula

The Court of Appeals affirmed the RTC judgment but modified the interest computation in accordance with Nacar v. Gallery Frames: 12% per annum from October 3, 2007 up to June 30, 2013, and 6% per annum from July 1, 2013 until full payment. The CA held that by issuing his personal check, petitioner represented personal responsibility for the face value and could not repudiate that representation to respondent’s prejudice.

Issue Presented to the Supreme Court

Whether the Court of Appeals erred in affirming petitioner’s civil liability for the face value of the dishonored check (P436,800.00), given petitioner’s acquittal of the criminal charge under B.P. 22.

Supreme Court Holding: Petition Denied; Petitioner Civilly Liable as Accommodation Party

The Supreme Court denied the petition and affirmed the CA decision with modification: petitioner is civilly liable as an accommodation party for RB Freight International, Inc., for the face value of the dishonored check, without prejudice to his right of recourse against RB Freight. The Supreme Court deleted the award of attorney’s fees and costs.

Analytical Framework: Acquittal and Sources of Civil Liability

The Court articulated two sequential premises guiding the analysis: (1) civil liability ex delicto arises from a criminal conviction; and (2) where there is an acquittal, civil liability ex delicto does not survive, and any remaining civil obligation must be based on another source under Article 1157 of the Civil Code (law, contract, quasi-contract, acts punished by law, or quasi-delicts) and proven by a preponderance of evidence. Because petitioner was acquitted for lack of proof beyond reasonable doubt, civil liability ex delicto was foreclosed; the Court therefore traced any surviving civil liability to another source.

Application of Premises: Contractual/Quasi-Contractual Source Found

The Court determined that although the underlying sale was between respondent and RB Freight (a corporate debt), the evidence established that petitioner signed and delivered his personal check as a means to secure credit for RB Freight. The transaction and the correspondence (demand letters addressed to RB Freight with attention to petitioner, RB Freight’s replies and Board actions) supported that the obligation was corporate in origin. The Court concluded that petitioner’s issuance of his personal check constituted an accommodation to RB Freight and therefore created a civil obligation independent of the criminal aspect.

Accommodation Party Under NIL Section 29 and Liability

Relying on Section 29 of the Negotiable Instruments Law and pertinent jurisprudence, the Court explained that an accommodation party is one who signs as maker, drawer, acceptor, or indorser without receiving value and for the purpose of lending his name to another. Such an accommodation party is liable to a holder for value notwithstanding lack of consideration. The Court found that petitioner’s issuance of a personal check to respondent, to enable continued credit and deliveries to RB Freight, fulfilled the elements of accommodation: he signed a personal check, did not receive value for it, and did so to lend his name for RB Freight’s credit. Petitioner’s characterization of the check as a mere “hold-out” did not negate that legal effect.

Precedential Support for Civil Liability Despite Acquittal

The Court cited cases (Chiok, Lumantas, Manantan) illustrating that an acquittal based on reasonable doubt does not automatically extinguish civil liability when evidence by preponderance shows an underlying obligation or causal nexus giving rise to civil liability. Under Article 29 of the Civil Code, civil actions after acquittal require on

Case Syllabus (G.R. No. 217682)

Case Caption, Court and Date

Supreme Court, First Division, G.R. No. 234329, Decision dated November 23, 2021.
Petition for Review on Certiorari under Rule 45 by Benjamin T. De Leon, Jr. (petitioner) seeking reversal of the Court of Appeals Special Fifteenth Division Decision in CA-G.R. SP No. 139973 dated April 20, 2017.
Decision authored by Justice Caguioa; concurrence by Chief Justice Gesmundo (Chairperson) and Justices Hernando and Lazaro-Javier. Notation regarding Members and wellness leave as in source.

Parties and Roles

Petitioner: Benjamin T. De Leon, Jr. — accused in the criminal case; admitted signing the check; alleged managing director of RB Freight International, Inc. (RB Freight).
Respondent / Private complainant: Roqson Industrial Sales, Inc. — seller of diesel products and holder of the dishonored check.
Third-party corporate actor: RB Freight International, Inc. — corporate purchaser of diesel from respondent; petitioner alleged to have acted on its behalf.

Underlying Facts / Transactional Background

Petitioner issued RCBC Check No. 0201234 dated August 25, 2006, in the amount of P436,800.00.
Upon presentment, the check was dishonored because it was drawn on a "closed account."
The diesel purchase underlying the check was for 12,000 liters of diesel, amounting to P436,800.00, and the sales transaction was between respondent and RB Freight.
Respondent treated the check as payment for deliveries of oil/diesel products made to RB Freight.
Respondent sent a series of demand communications: first demand letter dated September 15, 2006 addressed to RB Freight and petitioner; reply from RB Freight’s administrative manager, Mean Ramos, dated September 18, 2006 proposing settlement; respondent’s collection officer Alfredo D. Crisostomo sent a second letter agreeing to proposed settlement; RB Freight’s Board later rejected that proposal and requested a "debt moratorium" in a letter dated October 14, 2006.
Respondent sent a final demand letter by registered mail (registry receipt and return card on record); the final demand letter went unheeded.
Petitioner testified that he received no written notice of dishonor despite admitting issuance of the check.

Criminal Proceedings and Complaint

Criminal Case No. Q-07-145218: People of the Philippines vs. Benjamin T. De Leon, Jr., filed before Branch 40, Metropolitan Trial Court of Quezon City (METC) for violation of Batas Pambansa Blg. 22 (B.P. 22) for issuing a bouncing check.
Preliminary investigation by the City Prosecutor of Quezon City found probable cause to prosecute.
Trial evidence included the dishonored postdated check, demand letters, registry return receipts, and testimony of Alfredo D. Crisostomo.

METC Ruling (Trial Court, Metropolitan Trial Court)

Decision dated May 28, 2013: petitioner was acquitted of violation of B.P. 22 on the ground of reasonable doubt for failure of the prosecution to prove all elements of the crime, specifically petitioner’s knowledge of insufficiency of funds and receipt of notice of dishonor.
METC reasoning emphasized that registry return receipts and return cards presented bore unauthenticated signatures and thus did not prove actual receipt of notice beyond reasonable doubt.
METC held that prosecution must prove actual receipt of notice of dishonor; in criminal cases this requires clear proof beyond reasonable doubt.
Despite criminal acquittal, METC found petitioner civilly liable and ordered him to pay:
- The face value of the check: P436,800.00, with legal interest at 6% per annum from last demand dated November 3, 2006 until full payment;
- Attorney’s fees of P30,000.00 plus P2,000.00 per court appearance; and
- Costs of suit.
METC explained that acquittal on reasonable doubt does not necessarily extinguish civil liability and noted petitioner admitted contracting obligations on behalf of RB Freight as its managing director.

RTC Ruling (Regional Trial Court, Branch 226)

Judgment dated February 23, 2015: appeal dismissed for lack of merit; METC judgment affirmed with modification.
RTC modified legal interest and its reckoning date:
- Ordered legal interest at 12% per annum (citing Eastern Shipping Lines v. Court of Appeals) because case involves loans or forbearance of money, goods, or credits.
- Reckoned interest from date of judicial demand — filing of the Information on October 3, 2007 — because prosecution failed to prove when petitioner actually received notice of dishonor.
RTC reaffirmed acquittal for lack of proof beyond reasonable doubt but held petitioner personally liable for face value of the check because petitioner personally signed the check (Section 1 of B.P. 22); B.P. 22 punishes mere issuance of a bouncing check regardless of purpose.
RTC dismissed petitioner’s argument that debt was corporate and petitioner could not be personally liable; held signature on personal check made him personally liable.

CA Ruling (Court of Appeals, Special Fifteenth Division)

Decision dated April 20, 2017: petition for review under Rule 42 denied; RTC judgment affirmed with modification as to applicable legal interest.
CA applied Nacar v. Gallery Frames (2013) to hold:
- Civil amount P436,800.00 shall earn interest at 12% per annum from October 3, 2007 up to June 30, 2013, and 6% per annum from July 1, 2013 until full payment.
CA upheld lower courts’ finding that petitioner was personally liable for the dishonored check.
CA reasoning: petitioner issued his own personal check and thereby represented that he was personally answerable and had funds; he cannot retract that representation to respondent’s prejudice.
Petitioner’s motion for reconsideration of CA Decision was denied by CA Resolution dated September 15, 2017.

Petition to the Supreme Court and Relief Sought

Petitioner’s contentions on certiorari review:
- The debt was corporate (RB Freight’s) and, as managing director, petitioner should not be personally civilly liable; RB Freight should be held responsible.
- No finding of fraud or bad faith attributable to petitioner — no solidary liability.
- Acquittal on criminal charge should preclude civil liability.
Respondent’s counterarguments:
- The check was a personal check issued by petitioner; by issuing it petitioner assumed civil liability.
- Civil liability for issuance of an unfunded check is distinct from corporate obligation for the underlying purchase; petitioner has independent liability for the instrument.
- Petitioner acted as accommodation party for RB Freight and thus is liable; precedent Aglibot v. Santia invoked to show petitioner accommodated corporate debt by issuing personal checks.

Threshold Legal Issue Presented

Whether the Court of Appeals erred in affirming petitioner’s civil liability in favor of respondent for the face value of the check amounting to P436,800.00.

Supreme Court Ruling — Disposition

The petition is unmeritorious and is DENIED.
The Court of Appeals Decision dated April 20, 2017 and its Resolution dated September 15, 2017 are AFFIRMED with MODIFICATION as follows:
- Petitioner Benjamin T. De Leon, Jr. is found civilly liable as an accommodation party for RB Freight International, Inc.
- This civil liability is without prejudice to a separate civil action petitioner may pursue against RB Freight for reimbursement (right of recourse).
- The award of attorney’s fees and costs previously granted by the lower courts is deleted.
SO ORDERED.

Supreme Court’s Legal Analysis — Overarching Framework

Two sequential premises guided the Court’s analysis:
1. Civil liability arising from a violation of B.P. 22 is ex delicto in cha