Case Summary (G.R. No. 75243)
Transaction and Dishonor of Checks
The case arises from a business agreement where PMD Enterprises, owned by the Dingles, was to sell 400 tons of washed silica sand to Ernesto Ang. Nestor Dingle, who managed the family business, failed to fulfill this contract. Consequently, he issued two postdated checks, signed by both Nestor and Paz Dingle, amounting to P51,885.93 to Ang as compensation for the undelivered goods. These checks were subsequently dishonored due to insufficient funds. In an attempt to settle the matter, Nestor issued a bank check for the same amount, which also bounced.
Charges and Initial Sentencing
Following the dishonor of the checks, Nestor Dingle received two letters demanding payment, which he ignored. As a result, both spouses were charged with violating Batas Pambansa Blg. 22, the Anti-Bouncing Check Law. The trial court found them guilty, imposing a sentence of six months imprisonment for each, alongside a fine of P52,000.00 and an order to indemnify Ang the amount of P51,885.92.
Appeal and Intermediate Appellate Court Decision
Paz Dingle appealed the conviction, arguing her lack of knowledge regarding the bounced checks and the underlying transaction. The Intermediate Appellate Court modified the trial court's decision, reducing her sentence to 30 days of imprisonment. Despite this modification, Paz Dingle maintained her innocence and contended that she should not be held criminally liable.
Prosecution's Testimony and Acquittal
The Solicitor General supported her appeal, asserting that testimony from the prosecution witness, Ernesto Ang, indicated that he exclusively dealt with Nestor Dingle regarding the transaction. Ang did not implicate Paz Dingle in any manner, confirming that all communications, including the demand letters, were directed solely to Nestor. This established that Paz Dingle had signed the checks in blank without knowledge of their issuance or the relevant transaction.
Legal Principle Applied
The Supreme Court referenced the case of Florentino Lozano vs. Hon. Martinez, highlighting that a key element of the offense under Batas Pambansa Blg. 22 is the knowledge of the check
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Case Overview
- The case involves Paz M. Dingle as the petitioner against the Hon. Intermediate Appellate Court and the People of the Philippines as respondents.
- The petitioner's husband, Nestor Dingle, managed PMD Enterprises, a family business owned by the spouses.
- A transaction took place where PMD Enterprises was to sell 400 tons of washed silica sand to Ernesto Ang, who made an advance payment.
- Nestor Dingle's failure to deliver the silica sand led to the issuance of postdated checks which were subsequently dishonored.
Transaction and Issuance of Checks
- Nestor Dingle entered into an agreement with Ernesto Ang for the sale of washed silica sand.
- Ang made an advanced payment but did not receive the 400 tons of sand as promised.
- To settle the matter, Nestor issued two postdated checks totaling P51,885.93, drawn against PMD Enterprises’ account and signed by both spouses.
- These checks were dishonored due to "insufficient funds," prompting Nestor to issue a replacement check from Equitable Banking Corporation, which was also dishonored.
Legal Proceedings
- Following the dishonor of the checks, two demand letters were sent to Nestor Dingle, which he received b