Case Summary (G.R. No. 269745)
Background of the Case
George Rebujio was charged with a violation of Batas Pambansa Bilang 22 (BP 22), the law penalizing the issuance of checks drawn against insufficient funds. The case arose from a postdated check issued by Rebujio to DIPC for payment on behalf of BHMGI, which was subsequently dishonored due to insufficient funds. Despite being acquitted of criminal liability for the offense due to reasonable doubt, Rebujio was held civilly liable for the value of the dishonored check.
Proceedings in Lower Courts
Initially, the Metropolitan Trial Court acquitted Rebujio of the criminal charge but held him civilly liable based on evidence presented, concluding that while the prosecution had not established guilt beyond reasonable doubt, the civil aspect could still stand. The decision was reversed by the Regional Trial Court, which contended that civil liability could not exist in the absence of a criminal conviction.
Court of Appeals Decision
The Court of Appeals reinstated the ruling of the Metropolitan Trial Court, asserting that Rebujio, as the individual who issued the check, was liable for the amount despite the acquittal on criminal charges. The Appeals Court viewed the omission of the finance officer role from the list of corporate officers in the Corporation Code as irrelevant to the matter at hand, determining that the individual who signed the check could be held accountable.
Legal Arguments Presented
Rebujio contended that under existing jurisprudence, a corporate officer could not be held civilly liable without a prior conviction under BP 22. He referenced the case of Pilipinas Shell Petroleum Corporation v. Duque to support his argument about broad interpretations of corporate officers' roles. In response, DIPC claimed that Rebujio's actions demonstrated negligence and that as the signatory of the check, he could not hide behind corporate fiction to evade liability.
Main Issue for Review
The pivotal legal question was whether a finance officer like Rebujio could be held liable for the value of the dishonored check despite being acquitted of the criminal charge under BP 22.
Supreme Court Ruling
The Supreme Court ruled in favor of Rebujio, stating that an individual who has been acquitted of a violation of BP 22 cannot be held civilly liable for the associated debts arising from the issuance of a dishonored check. The ruling reinforced the understanding that civil liability ex delicto is extinguished upon acquittal, thereby preventing any civil liability stemming from the criminal act of issuing a bad check unless the individual is convicted.
Implications of the Decision
This ruling elucidates the distinction between civil and criminal liabilities, particularly in corporate contexts where individuals may act on behalf of corporations. The decision underscores the notion that liability for dishonored checks tied to corporate transactions fundamentally
...continue readingCase Syllabus (G.R. No. 269745)
Procedural Background
- The Petition for Review on Certiorari under Rule 45 challenges two Court of Appeals dispositions:
- The February 16, 2023 Decision reinstating the Metropolitan Trial Court's July 26, 2018 Decision that held George Rebujio civilly liable for the value of a dishonored check.
- The October 3, 2023 Resolution denying Rebujio's Motion for Reconsideration.
- The underlying case charged Rebujio with violation of Batas Pambansa Bilang 22 for issuance of a dishonored postdated check.
- Rebujio was acquitted of the criminal charge by the Metropolitan Trial Court but was held civilly liable for the amount of the check.
- The Regional Trial Court reversed the civil liability holding, stating civil liability attaches only after conviction.
- The Court of Appeals reversed the Regional Trial Court, reinstating the civil liability ruling.
- The Supreme Court now reviews this matter.
Facts of the Case
- George Rebujio, finance officer and authorized signatory of Beverly Hills Medical Group, Inc. (BHMGI), issued a Security Bank postdated check worth PHP 297,051.86 payable to Dio Implant Philippines Corporation (DIPC).
- The check was issued for payment of dental and cosmetic merchandise purchased by BHMGI through its in-house dentist, Dr. Maria Theresa Mendoza.
- Upon presentation, the check was dishonored for insufficient funds.
- Despite notice of dishonor and demand for payment, BHMGI did not settle the obligation.
- Rebujio contended that DIPC was not a supplier to BHMGI and that Dr. Mendoza acted in her personal capacity without BHMGI’s authorization.
- The prosecution failed to prove all elements of the crime; notably, it was not shown that Rebujio personally received notice of dishonor.
Issues Presented
- Whether Rebujio, as finance officer of BHMGI, can be held civilly liable for the value of the dishonored check despite his acquittal of the criminal charge under Batas Pambansa Bilang 22.
Applicable Law and Jurisprudence
- Batas Pambansa Bilang 22 (BP 22), Section 1, imposes criminal liability on anyone who issues a check without sufficient funds knowing of such insufficiency.
- When a check is drawn by a corporatio