Case Summary (G.R. No. 146211)
Background of the Case
The underlying events leading to the charges occurred on July 28, 1989, when Nagrampa, engaged as the General Manager of the Nagrampa Asphalt Plant, purchased a backhoe excavator from Fedcor for ₱200,000. He paid ₱50,000 in cash and issued two postdated checks for ₱75,000 each, dated August 31, 1989, and September 30, 1989. The checks were intended to cover the remaining balance for the excavator.
Nature of the Charges
The information in Criminal Case No. Q-90-15797 for estafa accused Nagrampa of defrauding Fedcor by issuing checks without sufficient funds in his bank account, leading to dishonor upon presentation. The subsequent charges for violations of B.P. Blg. 22 (Criminal Cases Nos. Q-90-15798 and Q-90-15799) were based on similar facts related to the dishonored checks.
Testimonies and Evidence
During the trial, Santander testified that Fedcor presented the checks for payment on February 22, 1990, but they were dishonored due to Nagrampa's account being closed since May 1985. The second witness, Felix Mirano, confirmed that the signatures on the checks matched Nagrampa's and substantiated that there were no funds available for payment at the time the checks were presented.
Trial Court's Ruling
On September 30, 1993, the Regional Trial Court convicted Nagrampa of the two counts of bouncing checks and imposed a sentence of two years of imprisonment along with a fine. Nagrampa appealed this decision, leading to additional scrutiny of the estafa case.
Court of Appeals' Decision
The Court of Appeals remanded the estafa case for resolution. On February 8, 1999, the trial court found Nagrampa guilty of estafa, resulting in a sentence of imprisonment ranging from seven years and four months to twelve years and six months. Nagrampa's subsequent appeal was affirmed by the Court of Appeals on July 21, 2000, leading to his challenge in the Supreme Court.
Arguments Presented
Nagrampa contended that no damages were incurred by Fedcor, claiming he returned the backhoe after it broke down. He argued that Fedcor failed to present the checks within the 90-day period, thus faulting them for the subsequent dishonor. He also suggested that if his conviction were upheld, a retroactive application of court rulings regarding penalties should be considered.
Respondent’s Counterarguments
The Office of the Solicitor General refuted Nagrampa's claims, emphasizing that the checks were inherently worthless at issuance due to the closed bank account. They maintained that the dishonor was assured regardless of deposit timing and that the evidence failed to support Nagrampa’s claims of returning the backhoe or lack of damages to Fedcor.
Legal Provisions Involved
The case references key provisions of Batas Pambansa Blg. 22, specifically Section 1, which addresses the elements of the offense—drawing checks without sufficient funds and failure to maintain funds within 90 days of issuance, thus rendering the checks dishonored.
Findings on Estafa
To establish the crime of estafa under paragraph 2(d) of Articl
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Case Overview
- This case involves a petition for review on certiorari by Manuel Nagrampa, who contests his conviction for estafa and violations of Batas Pambansa Blg. 22 (Bouncing Checks Law) in three separate criminal cases.
- The key dates relevant to the case include:
- July 28, 1989: The date of the alleged fraudulent transaction.
- February 22, 1990: The date the checks were presented for payment.
- March 19, 1990: The date FEDCOR sent a demand letter for payment.
Charges Against the Petitioner
- Criminal Case No. Q-90-15797: Estafa, based on the issuance of two postdated checks totaling P150,000 without sufficient funds.
- Criminal Cases Nos. Q-90-15798 and Q-90-15799: Violations of B.P. Blg. 22 concerning the issuance of checks that were dishonored for lack of funds.
Prosecution's Case
- The prosecution presented key witnesses:
- Federico Santander: President of Fedcor Trading Corporation, testified about the sale of a backhoe and the acceptance of postdated checks for the remaining payment.
- Felix Mirano: Signature verifier from Security Bank, confirmed that Nagrampa's bank account had been closed since May 1985, well before the checks were issued.
- Evidence showed that the checks were dishonored when presented, as the account had insufficient funds.
Defense's Arguments
- Nagrampa testified that he had paid a down payment of P50,000 and issued the checks for the remaining balance, asserting that he would replace t