Case Summary (G.R. No. 180643)
Facts of the Case
In December 1993, Yolanda Floro, engaged in the jewelry business, sold a 3-karat diamond, valued at P420,000.00, to Recuerdo. The petitioner issued nine postdated checks to settle the remaining balance, eight for P40,000.00 each, and one for P20,000.00. Upon deposit, only three of these checks were honored, while five were dishonored due to the closure of Recuerdo's bank account.
Proceedings at the Lower Courts
Yolanda Floro attempted to resolve the matter directly with Recuerdo, who failed to fulfill her promises to pay. Subsequently, a demand letter was sent, but Recuerdo did not respond. This led to the filing of five informations for violation of Batas Pambansa Blg. 22 at the Metropolitan Trial Court (MeTC) of Makati City, resulting in Recuerdo's conviction and a sentence comprising 30 days imprisonment for each count, along with a restitution amount of P200,000 and P20,000 in damages to Yolanda Floro.
Appeal and Arguments Presented
Recuerdo appealed the decision at the Regional Trial Court (RTC), which affirmed the earlier conviction, as did the Court of Appeals. In her petition for review, Recuerdo raised several contentions: the constitutionality of Batas Pambansa Blg. 22, her denial of due process, reliance on conjectural findings by the courts, and alleged bias from the Court of Appeals.
Constitutionality of Batas Pambansa Blg. 22
Recuerdo argued that the law was unconstitutional, asserting that it served as a mechanism for coercion and imposed penalties without due regard for intent or malice. However, the Supreme Court upheld the constitutionality of Batas Pambansa Blg. 22, emphasizing that the law targets the act of issuing worthless checks rather than the underlying debt. The Court clarified that proving the elements of the offense is required in court, stressing the public interest protected by the legislation.
Discussion on Due Process and Presumption of Innocence
Recuerdo claimed her right to presumption of innocence was violated. The Supreme Court found this argument unsubstantiated, noting that the prosecution's evidence sufficed to establish guilt beyond a reasonable doubt. The testimony of Yolanda Floro, regarding the dishonored checks, was deemed valid and competent, and the absence of a bank representative's testimony did not invalidate the prosecution's case.
Examination of Petitioner’s Claims
Recuerdo contended that the checks were not issued for deposit and referenced an alleged agreement with Yolanda regarding appraisal. Nonetheless, the Court held that such a claim did not absolve Recuerdo of responsibility under Batas Pambansa Blg. 22; the checks constituted evidence of debt regardless of t
...continue readingCase Syllabus (G.R. No. 180643)
Case Background
- The case is an appeal for review of the July 16, 1997 decision of the Court of Appeals in CA-G.R. No. 20577.
- The decision affirmed the ruling of the Regional Trial Court (RTC), Branch 150, Makati City.
- The RTC had previously affirmed the conviction of Joy Lee Recuerdo (petitioner) by the Metropolitan Trial Court (MeTC) of Makati City, Branch 67 for violating Batas Pambansa Blg. 22, commonly known as The Bouncing Checks Law, on five counts.
Facts of the Case
- In December 1993, Yolanda Floro, a jewelry business owner, sold a 3-karat loose diamond to the petitioner for P420,000.00, receiving a downpayment of P40,000.00.
- The petitioner issued 9 postdated checks to settle the remaining balance, comprising 8 checks for P40,000.00 each and 1 check for P20,000.00, all drawn against her Prudential Bank account.
- Upon deposit, only 3 of the checks cleared, while 5 were dishonored due to the closure of the petitioner’s bank account.
- Yolanda attempted to collect the amounts by visiting the petitioner’s dental clinic and sending a demand letter, which the petitioner ignored.
- Subsequently, 5 informations were filed against the petitioner for violations under B.P. 22.
Legal Proceedings
- The accusatory portion of the first information detailed that the petitioner issued a check to Yolanda knowing she had insufficient funds, which was dishonored upon presentation.
- The MeTC found the petitioner guilty on all counts, imposing a sentence of 30 days impr