Que v. People
REITERATIONFacts
1. The Antecedents: The case involves petitioner Victor Que, who was convicted by the Regional Trial Court of Quezon City for violating Batas Pambansa Blg. 22 on two counts. The conviction stemmed from the issuance of checks that were subsequently dishonored. The underlying dispute concerned purchases made by Powerhouse Supply, Inc., managed by the petitioner, for which the checks were issued. 2. Procedural History: The petitioner was convicted by the Regional Trial Court of Quezon City. This conviction was affirmed by the Intermediate Appellate Court (now Court of Appeals). Subsequently, the petitioner filed a Petition for Review on certiorari with the Supreme Court. The Supreme Court initially denied this petition through a minute resolution. The present document is a Resolution on a Motion for Reconsideration of that denial. 3. The Petition: The petitioner sought a review by certiorari of the appellate court's decision and resolution, arguing that the appellate court erred in not considering substantial questions of jurisdiction and in sanctioning the lower court's departure from accepted judicial procedures regarding jurisdiction. Specifically, the petitioner contended that the lower court lacked jurisdiction because a key element of the offense, the place of issuance of the check, was absent. The motion for reconsideration further argued that the denial of the petition by a minute resolution was improper and that the appellate court erred in not considering material facts showing a lack of jurisdiction and the absence of a principal element of the crime. The petitioner also questioned the appellate court's failure to consider that the checks were issued merely as a guarantee.
Issue(s)
Whether the Regional Trial Court of Quezon City had jurisdiction over the case for violation of Batas Pambansa Blg. 22. Whether Batas Pambansa Blg. 22 applies to checks issued merely as a guarantee for payment. Whether the denial of the petition for review by a minute resolution is proper.
Ruling
The motion for reconsideration is denied. The Supreme Court affirmed the decision of the appellate court, holding that the Regional Trial Court of Quezon City had jurisdiction, that Batas Pambansa Blg. 22 applies to checks issued as guarantees, and that denial by minute resolution is permissible.
Ratio Decidendi
On the jurisdiction of the Regional Trial Court: The Court held that the Regional Trial Court of Quezon City had jurisdiction over the case. This was based on Sections 10 and 15(a) of Rule 110 of the New Rules of Court. The findings of fact by the trial court, which were not disputed by the petitioner, indicated that the checks in question were issued in Quezon City. The petitioner himself inferentially admitted this in his answer to the civil complaint for collection of sum of money. The location of the bank where the checks were deposited is irrelevant; the determinative factor for jurisdiction is the place of issuance of the check. On the applicability of Batas Pambansa Blg. 22 to checks issued as guarantee: The Court affirmed the appellate court's finding that the petitioner's claim of issuing the checks merely to guarantee payment did not exculpate him from criminal liability. It is settled jurisprudence that Batas Pambansa Blg. 22 applies even when dishonored checks are issued as a deposit or guarantee. The law does not make any distinction regarding the purpose of the check's issuance. The legislative intent behind the enactment of Batas Pambansa Blg. 22 was to discourage the issuance of bouncing checks and to restore respectability to checks, making the prohibition all-embracing without exceptions for guarantees. This intent was evident from the deletion of a proviso in the original bill that would have excluded checks issued as guarantees. On the denial of the petition by a minute resolution: The Court addressed the petitioner's argument regarding the denial of his petition by a minute resolution. Citing the case of In Re: Almacen, the Court reiterated that such minute resolutions are not 'decisions' within the meaning of the constitutional requirement for stated reasons. They merely signify that the petition for review is not to be entertained due to lack of merit or because it is not a matter of right but of sound judicial discretion. The facts and law are already laid out in the Court of Appeals' opinion, thus obviating the need for a detailed explanation in a denial resolution.
Main Doctrine
The place of issuance of a dishonored check is the determinative factor for jurisdiction in cases of violation of Batas Pambansa Blg. 22. The law applies regardless of whether the check was issued as payment or as a guarantee.