Case Summary (G.R. No. L-31494)
Nature of Charges
The Regional Trial Court of Malabon initiated cases for estafa against the Lim spouses based on three counts under Article 315, paragraph 2(d) of the Revised Penal Code, and seven counts of violations of B.P. Blg. 22. The charges were predicated on the issuance of checks as payment for goods from LINTON after the checks were dishonored when presented to the drawee bank.
Background of Transactions
The Lims had a history of business transactions with LINTON, whereby they regularly received materials on credit. Specific transactions, including orders for steel plates and purlins exceeding P350,000, culminated in the issuance of multiple checks. Deposited checks were dishonored due to both insufficiency of funds and payment stoppage.
Evidence Presented
Testimonies from LINTON's officials confirmed the dishonor of checks presented for payment and failure of the Lim spouses to rectify the situation by making payment despite notification. The Lims maintained a balance in their bank account when the checks were issued but argued that the checks were stopped due to disputes over the quality of goods delivered.
Court's Findings at Trial Level
The trial court convicted the Lim spouses of both estafa and violations of B.P. Blg. 22, imposing various sentences and requiring indemnification to LINTON for the amounts represented by the dishonored checks. The court found that the issuance of checks constituted a fraudulent act given the condition of the Lims' bank account at the time of both the issuance and presentment of the checks.
Appeals and Key Arguments
On appeal, the Lim spouses contended that the Regional Trial Court lacked jurisdiction as the offenses were committed outside its territorial limits. They also argued that they should not be liable for estafa since the checks were issued after delivery and asserted their account had sufficient funds to cover the checks. Moreover, they claimed the dishonored checks were ordered stopped due to non-conformance of goods delivered.
Ruling of the Court of Appeals
The Court of Appeals acquitted the Lim spouses of estafa but upheld the conviction for B.P. Blg. 22, affirming that they violated the law by knowingly failing to maintain sufficient funds for the checks presented. The appeals court reinforced that the timing and context of the checks’ issuance were critical, stating that liability stemmed from the willful act of issuing checks without adequate funds.
Jurisdiction and Venue Considerations
The appeal also raised issues regarding the proper jurisdiction, with the petitioners asserting that the relevant actions occurred in Kalook
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Case Overview
- The case involves Manuel Lim and Rosita Lim, spouses charged with estafa and violations of the Bouncing Checks Law (B.P. Blg. 22).
- It was docketed as G.R. No. 107898 and decided on December 19, 1995, by the First Division of the Supreme Court of the Philippines.
- The case stems from transactions with Linton Commercial Company, Inc. (LINTON) involving dishonored checks issued by the Lims.
Charges and Background
- The Lims faced three counts of estafa under Article 315, par. 2 (d) of the Revised Penal Code for issuing checks without sufficient funds.
- They were also charged with seven counts of violation of B.P. Blg. 22 for issuing checks knowing they lacked funds.
- The checks were issued as payment for goods delivered by LINTON, including mild steel plates and purlins, with amounts totaling significant sums.
Details of Transactions
- Transactions included orders for:
- 100 pieces of mild steel plates valued at P51,815.00.
- Additional orders for 65 pieces of mild steel plates worth P63,455.00.
- 2,600 "Z" purlins totaling P241,800.00 delivered over multiple dates.
- The Lims issued various SOLIDBANK checks as payment, which were subsequently dishonored due to insufficient funds or payment being stopped.
Evidence and Testimonies
- William Yu Bin, Vice President of LINTON, confirmed the dishonor of checks upon their deposit.
- Salvador Alfonso, a signature verifier from SOLIDBANK, provided details on the dishonor reasons, indicating both "payment stopped" and "drawn