G.R. No. L-66003-04 - People vs. Manzanilla

Case Summary (G.R. No. L-66003-04)

Factual Background

The facts were treated as uncontroverted. On January 12, 1980, Lourdes Tan Chua entered into a contract with New C. T. Glass and Aluminum General Merchandise, a retail firm based in Bacolod City managed by Antonio Yu, for the supply of swing doors, wall panels, and similar goods to be installed in her building in Iloilo City. The total contract cost was P370,000.00.

In payment, the Chuas issued two postdated checks drawn against the Metropolitan Bank and Trust Company (Iloilo City Branch). One check, for P10,000.00, was signed by Johnny Tan Chua; the other, for P15,000.00, was signed by Lourdes Tan Chua. Both checks were drawn and signed in Iloilo City. Seasonably, the checks were deposited with the Metropolitan Bank and Trust Company, Bacolod City Branch, but both were dishonored for “insufficient funds.” Despite due demands to make good the checks, the Chuas failed to pay.

The informations were filed after preliminary investigation, and they were consolidated for joint proceedings.

Filing of Criminal Informations and Early Proceedings

After the preliminary investigation, the City Fiscal of Bacolod City filed separate informations against both private respondents for violation of Batas Blg. 22. The cases were thereafter consolidated. After joint arraignment, the Chuas moved to dismiss, invoking lack of jurisdiction. The trial court at the time, presided over by Judge Segundino Chua, denied the motion and proceeded to trial. The prosecution rested on September 23, 1982.

Second Motion to Dismiss and the Trial Court’s Dismissals

After the prosecution had rested, the Chuas filed a second motion to dismiss on June 21, 1983, again insisting that the court lacked jurisdiction and that the evidence was insufficient to secure conviction. By August 9, 1983, with a new judge presiding—respondent Judge Herberto A. Manzanilla—the trial court issued the first of the two challenged orders dismissing the cases on the ground of lack of jurisdiction, reasoning that the offenses had been allegedly consummated in Iloilo City. On October 18, 1983, the trial court denied reconsideration.

In its orders, the respondent judge took the view that jurisdiction to try the cases was vested in the Regional Trial Court in Iloilo City, since the checks were allegedly connected to the place of dishonor.

Appellate Issues and the Court’s Focus

Although the parties raised multiple issues, the Supreme Court treated the jurisdictional question as decisive. The Supreme Court evaluated whether the trial court in Bacolod City had jurisdiction despite the respondent judge’s position that the offense was consummated in Iloilo City.

The Parties’ Contentions on Jurisdiction

The respondent judge held that jurisdiction belonged to the Regional Trial Court in Iloilo City on the theory that the checks were dishonored there. The People, by contrast, argued that the checks, though related to the drawer and drawee locations, were delivered to the payee in Bacolod City, and that this factual allegation supported filing in Bacolod City.

Legal Basis: Elements of the Offense and the Role of Dishonor

The Supreme Court began with the statutory characterization of the offense under Batas Blg. 22, Sec. 1. It noted that the offense was committed when the accused “makes or draws and issues any check to apply on account or for value, knowing at the time of issue that he does not have sufficient funds,” or when, having sufficient funds or credit, the accused “shall fail to keep sufficient funds or to maintain a credit” to cover the full amount of the check if presented within ninety (90) days from the date appearing thereon, and the check is dishonored by the drawee bank.

Against the respondent judge’s ruling, the Supreme Court held that dishonor was only one ingredient and not the sole determinant of jurisdiction. It observed that the respondent judge had discounted other elements, including the making or drawing and issuing of the worthless checks and the knowledge by the drawer at the time of issue that there were insufficient funds to cover the checks. The Supreme Court further found that in the case at bar, it was not disputed that the private respondents knew at the time they issued the checks that they lacked sufficient funds in the drawee bank.

The Supreme Court treated knowledge, as an essential statutory ingredient defined in Batas Blg. 22, as a continuing eventuality. Therefore, it could support jurisdiction in the proper forum even if the accused were located in different territorial areas. The Court concluded that this doctrinal understanding was “sufficient to confer jurisdiction upon the trial court.”

Legal Basis: Malum Prohibitum and Reliance on the Information’s Allegations

The Supreme Court also characterized violation of Batas Blg. 22 as malum prohibitum, meaning the offense was committed by the very fact of its performance. In that legal setting, it held that jurisdiction or venue was determined by the allegations in the information.

Applying this principle, the Court observed that the information alleged that the offense was committed in Bacolod City. Consequently, it held that the legal requirements stated in Rule 110, Section 15 of the Revised Rules of Court, as amended, were substantially complied with. The Court relied on precedents cited in the source material to support the proposition that venue and jurisdiction in this context turn on what was alleged in the information and on substantial compliance with the procedural requirements.

Disposition and Remand

For these reasons, the Supreme Court ruled against the trial court’s dismissal. It reversed and set aside the orders dated August 9, 1983 and October 18,

Case Syllabus (G.R. No. L-66003-04)

The People of the Philippines appealed under Republic Act No. 5440 from two orders of the Regional Trial Court of Negros Occidental, Bacolod City (Branch XLVII), which dismissed two criminal cases for alleged violation of Batas Blg. 22.
The dismissals were directed against the private respondents, Johnny Tan Chua and Lourdes Tan Chua, identified in the records as son and mother, respectively.
The appealed orders were issued by respondent Judge Herberto A. Manzanilla, who ruled that the trial court lacked jurisdiction because the offenses were allegedly consummated in Iloilo City.
The controversy proceeded on appeal on the decisive jurisdictional question concerning proper venue and the situs of the offense under Batas Blg. 22.

Parties and Procedural Posture

The People of the Philippines served as the appellant, invoking Republic Act No. 5440 as the procedural vehicle for the appeal.
The respondents were Hon. Herberto A. Manzanilla, Presiding Judge of Branch XLVII, Regional Trial Court of Negros Occidental, Bacolod City, and the private respondents Lourdes Tan Chua and Johnny Tan Chua.
The private respondents first moved to dismiss after arraignment on the ground of lack of jurisdiction, and the trial court denied the motion while then presided over by Judge Segundino Chua.
The case proceeded to trial, and the prosecution completed its presentation on September 23, 1982.
After a new judge took over, the private respondents filed a second motion to dismiss, again raising lack of jurisdiction and insufficiency of evidence, and the trial court granted the jurisdictional challenge.
The trial court issued an order on August 9, 1983 dismissing the cases for lack of jurisdiction, and later denied reconsideration on October 18, 1983, prompting the present appeal.

Key Factual Allegations

On January 12, 1980, Lourdes Tan Chua entered into a contract with New C. T. Glass and Aluminum General Merchandise, a retail firm in Bacolod City managed by Antonio Yu, for the supply of swing doors, wall panels, and similar goods to be installed in her building in Iloilo City.
The total contract price was P370,000.00.
In payment, the private respondents issued checks drawn on Metropolitan Bank and Trust Company (Iloilo City Branch).
Two postdated checks were issued: one dated for September 30, 1980 for P10,000.00, and another dated for November 30, 1980 for P15,000.00.
Johnny Tan Chua signed the first check and Lourdes Tan Chua signed the second check.
The checks were drawn and signed in Iloilo City, while they were later deposited with the Metropolitan Bank and Trust Company, Bacolod City Branch.
The checks were dishonored for “insufficient funds.”
The payee made due demands upon the private respondents to make good the checks, but they failed.
After preliminary investigation, the City Fiscal of Bacolod City filed separate informations for violation of Batas Blg. 22, and the cases were consolidated.

Informations and Consolidation

The prosecution filed two separate informations for violation of Batas Blg. 22, corresponding to the two dishonored checks.
The informations alleged that the offense was committed in Bacolod City, as stated in the Court’s discussion of the jurisdictional allegations.
After joint arraignment, the private respondents moved to dismiss, which led to consolidation having already been established in the trial court proceedings.

Statutory Framework

Batas Blg. 22, Sec. 1 penalizes the act of “mak[ing] or draw[ing] and issu[ing] any check to apply on account or for value, knowing at the time of issue that he does not have sufficient funds”.
The same provision also penalizes the failure to keep sufficient funds, where a drawer having funds shall “fail to keep sufficient funds or to maintain a credit to cover the full amount of the check if presented within a period of ninety (90) days from the date appearing thereon, for which reason it is dishonored