Case Summary (G.R. No. 199067)
Facts of the Case
Purificacion Felipe's son, Frederick Felipe, purchased a Nissan Terrano vehicle valued at P1,020,000.00 from Nissan Gallery-Ortigas, attracted by a substantial discount. The transaction was intended to be cash-on-delivery without an initial down payment. The vehicle was delivered on May 14, 1997, yet Frederick did not make the payment. Subsequently, Nissan attempted to collect the owed amount through demand letters but received no payment. Eventually, Frederick requested his mother Purificacion to issue a check for his debt. Upon presentation, the check was dishonored due to a stop payment order.
Initial Legal Proceedings
Following the dishonor of the check, Nissan served a demand letter to Purificacion but she refused to replace the check, asserting that she was not involved in the vehicle purchase. Consequently, Nissan filed a criminal complaint against Purificacion for violating BP 22. During preliminary investigations, Purificacion made a partial payment but later failed to fulfill the remaining obligation. The Metropolitan Trial Court (MeTC) ultimately acquitted her of the criminal charge while holding her civilly liable for the amount of P675,000.00, leading to an appeal.
Regional Trial Court Decision
Upon appeal, the Regional Trial Court affirmed the MeTC's judgment, ruling that Purificacion was estopped from denying her involvement as an accommodation party to Frederick’s debt. It was concluded that she was liable for the civil aspect of the case, even in light of her acquittal of the criminal charge.
Court of Appeals Ruling
On further appeal to the Court of Appeals, it reversed the previous decision, stating that there was no contractual relationship between Nissan and Purificacion. The appellate court emphasized that Purificacion could not be held civilly liable because her acquittal from the criminal charge was definitive. It ruled that her act of issuing the check did not imply a civil obligation to Nissan.
Supreme Court Jurisdiction
Nissan Gallery-Ortigas then filed a petition seeking to reverse the Court of Appeals' ruling. The key legal question presented was whether Purificacion could be held civilly liable for issuing a worthless check despite her criminal acquittal.
Supreme Court Decision
The Supreme Court ruled in favor of Nissan, affirming that a civil action is inherently included in a criminal complaint for violations of BP 22. It stated that the act of issuing a dishonored check itself establishes civil liability as the underlying act from which the
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Case Background
- This case originates from a petition for review on certiorari filed by Nissan Gallery-Ortigas against Purificacion F. Felipe, challenging the June 30, 2011 Decision and October 21, 2011 Resolution of the Court of Appeals (CA) regarding a criminal complaint for violation of Batas Pambansa Blg. 22 (BP 22).
- Nissan, a car dealership, initiated a complaint against Purificacion for issuing a postdated check for P1,020,000.00, which was dishonored due to a stop payment order.
- The check was issued in connection with the purchase of a Nissan Terrano 4x4 SUV by Purificacion’s son, Frederick Felipe, who initially failed to pay upon delivery.
Facts of the Case
- Frederick purchased the vehicle under a cash-on-delivery term without a downpayment on May 14, 1997, but did not pay the amount due.
- Despite several demand letters from Nissan, Frederick did not fulfill his payment obligation and requested a grace period, which he subsequently failed to honor.
- On November 25, 1997, Frederick asked Purificacion to issue the check to settle his obligation, resulting in the issuance of a postdated check.
- The check was dishonored upon presentment, and Nissan subsequently sent a demand letter to Purificacion, which she refused to honor, citing her