Lazaro v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Marlyn Lazaro was charged with Estafa and Violation of Batas Pambansa Bilang 22 (B.P. 22). The prosecution established that Lazaro received P90,000.00 from complainant Rudy Chua as advance payment for ordered goods. Lazaro made a partial delivery worth P18,000.00 and issued Prudential Bank Check No. 599175 for P72,000.00 as a refund for the undelivered portion. This check was dishonored for being drawn against an "Account Closed." Lazaro then indorsed another check, Trader's Royal Bank Check No. 393173, which was also dishonored for the same reason. Chua sent a demand letter for payment, and upon failure to pay, filed the criminal complaints. Procedural History: The Regional Trial Court (RTC), Branch 86, Quezon City, rendered a joint decision finding Lazaro guilty of Violation of B.P. 22, sentencing her to one year imprisonment and to indemnify Rudy Chua in the sum of P72,000.00. She was acquitted of the estafa charge. The Court of Appeals (CA) affirmed the RTC decision in toto, and a subsequent motion for reconsideration was denied. The Petition: Petitioner Marlyn Lazaro filed a petition for review, raising issues that the CA decision was contrary to the evidence, that the CA committed grave abuse of discretion by disregarding the fact that her obligation was settled by a Deed of Sale of her car, and that the CA erred in affirming the lower court's judgment.
Issue(s)
Whether the Court of Appeals erred in affirming the trial court's decision finding the petitioner guilty of Violation of Batas Pambansa Bilang 22. Whether the petitioner's obligation was extinguished by the execution of a Deed of Sale of her car to the complainant, thereby negating the violation of B.P. 22, and whether prejudice or damage to the offended party is a prerequisite for conviction under B.P. 22. On the issue of the indemnity awarded despite the alleged extinguishment of obligation.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals in toto, upholding the conviction of Marlyn Lazaro for Violation of Batas Pambansa Bilang 22.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in affirming the trial court's decision finding the petitioner guilty of Violation of Batas Pambansa Bilang 22: The Court held that the petitioner's argument is without merit. Citing Que vs. People, the Court reiterated that the clear intention of the framers of Batas Pambansa Bilang 22 is to make the mere act of issuing a worthless check malum prohibitum. Consequently, prejudice or damage to the complainant is not a prerequisite for conviction under B.P. 22. The Court further emphasized, in line with People vs. Nitafan, that the agreement surrounding the issuance of the checks need not be examined, as the law clearly provides that the mere issuance of any kind of check, regardless of the parties' intent (whether as a guarantee or deposit), which is subsequently dishonored, makes the issuer liable. The law's intent is to curb the proliferation of worthless checks as a means of payment. On the issue of whether the petitioner's obligation was extinguished by the Deed of Sale and if prejudice is a prerequisite for conviction under B.P. 22: The Court held that the petitioner's argument is without merit. Citing Que vs. People, the Court reiterated that the clear intention of the framers of Batas Pambansa Bilang 22 is to make the mere act of issuing a worthless check malum prohibitum. Consequently, prejudice or damage to the complainant is not a prerequisite for conviction under B.P. 22. The Court further emphasized, in line with People vs. Nitafan, that the agreement surrounding the issuance of the checks need not be examined, as the law clearly provides that the mere issuance of any kind of check, regardless of the parties' intent (whether as a guarantee or deposit), which is subsequently dishonored, makes the issuer liable. The law's intent is to curb the proliferation of worthless checks as a means of payment. On the issue of the indemnity awarded despite the alleged extinguishment of obligation: The Court stated that even if the obligation of Marlyn Lazaro to complainant Chua was extinguished by the conveyance of her car, this does not justify the cancellation of the indemnity awarded. The Court noted that B.P. 22 provides for a fine which may be imposed by the court, not exceeding double the amount of the dishonored check. Citing Esler vs. Ledesma, the Court clarified that a fine is a pecuniary punishment imposed by a lawful tribunal upon a person convicted of a crime. The fine provided for in B.P. 22 was intended as an additional penalty for the act of issuing a worthless check, which is the only logical conclusion given that the law does not require damage or prejudice to the complainant.
Main Doctrine
Under Batas Pambansa Bilang 22, the mere act of issuing a worthless check is considered malum prohibitum, and prejudice or damage to the complainant is not a prerequisite for conviction. The law aims to curb the proliferation of worthless checks as a means of payment, and the agreement surrounding the issuance of the check, whether intended as a guarantee or deposit, is irrelevant if the check is subsequently dishonored.