G.R. No. 149275 - Ty vs. People

Case Summary (G.R. No. 149275)

Applicable Law and Charges

The case was decided under the 1987 Philippine Constitution and involved charges under B.P. 22, which penalizes the making, drawing, and issuance of checks without sufficient funds or credit. The prosecution hinged on the presumption that the issuance of dishonored checks is prima facie evidence of knowledge of insufficiency of funds unless proven otherwise.

Background of the Case and Checks Issued

Seven checks, each amounting to ₱30,000.00, were issued by petitioner to Manila Doctors’ Hospital between November 1992 and May 1993 as payment for hospital bills of petitioner’s mother and sister. All checks were postdated and subsequently dishonored by Metrobank with the reason “Account Closed.” Demand letters for payment sent by registered mail were ignored, prompting filing of criminal charges.

Trial Court Proceedings and Findings

At trial, petitioner pleaded not guilty. The prosecution presented evidence showing that petitioner’s mother and sister incurred hospital bills amounting to over ₱1 million, and that petitioner signed an acknowledgment of financial responsibility and a promissory note for installment payments. The court found petitioner guilty, ruling that she issued the checks in payment of a legitimate obligation and rejecting her defense of coercion and uncontrollable fear.

Petitioner’s Defense

Petitioner claimed that the issuance of the checks was under “uncontrollable fear” and compulsion, alleging the hospital threatened not to discharge her mother unless bills were paid and that her mother suffered inhuman treatment. Petitioner argued absence of valuable consideration for the checks and contended the hospital knew about the insufficiency of funds in her account.

Court of Appeals’ Decision

The Court of Appeals affirmed the trial court’s conviction but modified the penalty to a fine of double the total amount of the checks, dispensing with imprisonment. The appellate court rejected petitioner’s defenses, emphasizing that B.P. 22 punishes the mere issuance of a worthless check regardless of purpose or conditions attached and that valuable consideration was present as the hospital provided services.

Legal Principles on Uncontrollable Fear and State of Necessity

The Court carefully analyzed the defense of uncontrollable fear, explaining that it requires: (1) an actual, imminent, and grave threat; (2) that such fear would overcome an ordinary person’s will; and (3) the injury feared must be greater than or equal to the harm caused. Petitioner failed to prove these, as the alleged fear related to speculative and non-immediate harms, such as the possibility of her mother committing suicide or suffering further unethical treatment. Similarly, the defense of state of necessity was dismissed for lack of actual, imminent evil and the availability of less harmful alternatives such as offering jewelry as collateral.

Presumption of Consideration and Knowledge of Insufficiency of Funds

Upon issuance, checks are presumed to be supported by valuable consideration under Section 24 of the Negotiable Instruments Law. Petitioner failed to overcome this presumption with convincing evidence. Since the hospital provided actual services to petitioner’s mother and sister, the obligation was valid, regardless of petitioner not being the patient. Moreover, under B.P. 22, knowledge of insufficiency of funds is legally presumed once the checks are dishonored and presented within ninety (90) days, shifting the burden onto the maker to provide evidence to rebut it, which petitioner did not do. The knowledge of the payee about the insufficiency of funds is immaterial to liability.

Jurisprudence on the Nature of Offense and Liability

The Court underscored that violation of B.P. 22 is a malum prohibitum offense, penalizing the act of issuing worthless checks without regard to intent or deceit. Unlike the case relied upon by petitioner (Magno v. Court of Appeals), which involved a peculiar transactio

Case Syllabus (G.R. No. 149275)

Facts of the Case

Petitioner Vicky C. Ty was charged and found guilty by the Regional Trial Court (RTC) of Manila, Branch 19, for seven counts of violation of Batas Pambansa Blg. 22 (B.P. 22), also known as the Bouncing Checks Law.
The case arose from seven (7) postdated checks drawn by Ty payable to Manila Doctors Hospital, each in the amount of P30,000, which were dishonored due to insufficient funds or account closure.
The total hospital bills amounted to over P1,000,000 for treatments availed by Ty’s mother and sister at Manila Doctors Hospital.
Ty had signed an Acknowledgment of Responsibility for Payment and a Promissory Note to pay the hospital bills in installments.
Each check was delivered as payment assurance but was dishonored when presented for payment within ninety (90) days.
After demand letters went unheeded, the hospital filed seven separate Informations consolidated into one trial before the RTC.
Ty pleaded not guilty and claimed her issuance of the checks was compelled by uncontrollable fear due to the hospital's alleged inhumane treatment of her mother, which she argued was an avoidance of a greater injury.

Issues Presented

Whether the issuance of the bounced checks was voluntary or compelled by uncontrollable fear or avoidance of a greater evil.
Whether the checks were supported by valuable consideration.
Whether knowledge by the hospital of the insufficiency or closure of the bank account exempts Ty from criminal liability.
Whether the penalty of imprisonment was appropriate or if a fine should be imposed instead.
Whether the principles of justice, equity, or justifying circumstances such as state of necessity apply.

Trial Court Findings and Judgment

The RTC found Ty guilty of seven counts of violation of B.P. 22 and sentenced her to six months imprisonment per count (total of forty-two months).
It rejected Ty’s defense of uncontrollable fear and held that the checks were issued as payment for a valid obligation.
The trial court emphasized that the dishonor of checks due to insufficient funds met the requisites of the offense under B.P. 22.

Court of Appeals Decision

The Court of Appeals affirmed the RTC’s guilt finding but modified the penalty from imprisonment to payment of a fine equivalent to double the amount of each bounced check (P60,000 per check).
It dismissed the defense of involuntariness and knowledge of insufficiency on the part of the payee, reiterating that the offense punishes the issuance of a bad check, a malum prohibitum act.
The Court applied precedents emphasizing that the object of the law is the act of issuing worthless checks regardless of purpose or conditions.
It referenced the Indeterminate Sentence Law and related jurisprudence encouraging alternatives to imprisonment to preserve human dignity and economic usefulness where applicable.

Supreme Court’s Ruling

The Supreme Court denied the Petition for Review, affirming the Court of Appeals’ decision with modifications r