Case Summary (G.R. No. 185522)
Growth of Business and Accounting Difficulties
As respondent’s weekly orders rose from 200 to 4,000 cases, tracking transactions became onerous. She repeatedly requested detailed statements from SMC, which were not furnished.
Issuance of Postdated Checks and Account Discrepancy
In late 2000, SMC’s agent required respondent to issue several postdated checks anticipating the Christmas season surge, again without an itemized balance. After partial cash payments and returns of empties, respondent discovered an unexplained substantial balance. To compel a detailed statement and protect her rights, she instructed her bank to stop payment on seven outstanding checks totaling ₱921,215.00. SMC responded on October 19, 2000, with a demand for the full value of the dishonored checks.
Offer of Compromise and Subsequent Criminal Complaint
On December 5, 2000, respondent’s counsel submitted an “Offer of Compromise,” acknowledging receipt of a statement demanding ₱816,689.00 and proposing a settlement plan. SMC did not accept the proposal and filed a criminal complaint on March 9, 2001, alleging violation of the Bouncing Checks Law.
Trial Court Findings on Criminal and Civil Liability
The Metropolitan Trial Court acquitted respondent of the criminal charge but held her civilly liable for ₱71,009—the net balance as shown in the eventually furnished Statement of Account. The Regional Trial Court and Court of Appeals affirmed, as double jeopardy barred appeal of the acquittal, and SMC pursued only the civil aspect.
Issues on Review
- Whether the Offer of Compromise constituted an admission of liability or guilt.
- Whether SMC proved respondent’s indebtedness in the full amount of ₱921,215.00.
Analysis on Offer of Compromise
Under Rule 130, Section 27, an offer of compromise in civil cases is privileged and inadmissible as an admission of liability; in criminal cases, such offers pre-filing are outside the context of a criminal proceeding and cannot be deemed implied admissions of guilt. The letter merely acknowledged receipt of a statement of account, not liability, and was rescinded by respondent, who testified to threats by SMC agents and uncertainty regarding her true debt. The trial courts’ acceptance of these justifi
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Facts of the Case
- Helen T. Kalalo was a dealer of San Miguel Corporation (SMC) beer products beginning in 1998 under a credit overdraft arrangement.
- Prior to each delivery, Kalalo issued two checks to SMC: one blank check and one for the gross value of goods.
- Weekly, SMC and Kalalo computed the net amount due by deducting the value of returned empty bottles and cases from the gross value; the net amount was then filled in on the blank check, and Kalalo funded her account to cover it.
- As Kalalo’s business expanded to 4,000 cases per week, she struggled to track deliveries and requested regular statements of account, which SMC failed to provide.
- In 2000, anticipating higher Christmas‐season orders, SMC required Kalalo to issue several postdated checks without disclosing the underlying balance breakdown; she complied but still faced a substantial alleged deficiency.
- To compel an updated account, Kalalo stopped payment on seven checks dated between September 16 and October 14, 2000, totaling ₱921,215.00.
- Instead of reconciling the account, SMC sent a demand letter for the full value of the dishonored checks on October 19, 2000.
- On December 5, 2000, under alleged threats of imprisonment by SMC agents, Kalalo’s counsel sent an “Offer of Compromise” acknowledging receipt of a statement demanding ₱816,689.00 and proposing installment payments.
- SMC did not accept the compromise and, on March 9, 2001, filed a criminal complaint against Kalalo for violation of Batas Pambansa Blg. 22 (Bouncing Checks Law).
- After the prosecution rested, SMC finally provided a Statement of Account showing a net balance of ₱71,009.00 owed by Kalalo, crediting cash payments