Case Summary (G.R. No. 200090)
Factual Background
In 2005, San Mateo placed an order for yarns and issued 11 postdated Metrobank checks as partial payment. Despite repeated requests to defer depositing the checks due to insufficient funds, Sehwani deposited one check, which was subsequently dishonored for lack of funds. San Mateo continued to fail to make payments, resulting in additional dishonored checks and her eventual being charged with multiple counts of violating Batas Pambansa (B.P.) 22.
Lower Courts' Findings
The Metropolitan Trial Court (MeTC) found San Mateo guilty of 10 counts of B.P. 22 and imposed a penalty of imprisonment and a civil liability amounting to P134,275.00. The Regional Trial Court (RTC) affirmed this conviction, asserting that the elements of the violation were sufficiently proven. The findings indicated that the notice of dishonor and San Mateo's refusal to accept communication regarding her checks established her liability.
Appeal to the Court of Appeals
The Court of Appeals (CA) upheld the RTC's decision, reiterating that the prosecution demonstrated all elements necessary for a conviction under B.P. 22. San Mateo’s claims of an agreement with Sehwani to defer deposits were deemed not credible enough to negate her liability.
Grounds for Supreme Court Petition
In her petition to the Supreme Court, San Mateo raised three critical issues: the presence of valuable consideration for the checks, whether the demand letter constituted an adequate notice of dishonor as required by B.P. 22, and the appropriateness of the penalty of imprisonment.
Supreme Court's Analysis of the Petition
The Supreme Court determined that the first and third elements of the violation were present, but the second element—demonstrating that San Mateo knew about the insufficiency of her funds—was not sufficiently established. The presumption of knowledge is contingent upon the issuer's receipt of proper written notice of dishonor, which was not proven in this case.
Notice of Dishonor
The court stressed that actual receipt of notice is crucial; mere sending or attempted delivery does not suffice. The prosecution's failure to conclusively prove that San Mateo received the demand letters meant that the assumption of her knowledge of insufficient funds could not be invoked, which is essential for a conviction under
...continue readingCase Syllabus (G.R. No. 200090)
Case Overview
- Case Citation: 705 Phil. 630, G.R. No. 200090, March 06, 2013
- Parties Involved: Erlinda C. San Mateo (Petitioner) vs. People of the Philippines (Respondent)
- Judicial Division: Third Division
- Decision Author: Justice Abad
Factual Background
- In May and July 2005, Erlinda C. San Mateo ordered assorted yarns from ITSP International, Incorporated, totaling P327,394.14.
- As partial payment, San Mateo issued 11 postdated checks amounting to P134,275.00.
- Despite the issuance of checks, San Mateo regularly requested the Vice-President for Operations, Ravin A. Sehwani, not to deposit them due to insufficient funds.
- San Mateo's checks began to bounce, starting with Check 917604197 on October 6, 2005, which was dishonored for insufficient funds.
- Following this, San Mateo continued to communicate her financial difficulties and requested deferrals for check deposits.
- On November 7, 2005, she issued a stop payment order for another check, which was also dishonored.
- Throughout this period, Sehwani attempted to contact San Mateo for payment but received no response.
- Demand letters sent to San Mateo were either refused by the security guard or returned due to her not claiming them.
- Subsequently, on June 5, 2006, San Mateo was charged with 11 counts of violation of Batas Pambansa (B.P.) 22.
Trial Court Proceedings
- The Metropolitan Trial Court (MeTC) found San Mateo guilty on August 27, 2009, of 10