Yulo v. People
REITERATIONFacts
The Antecedents: Lilany Yulo (petitioner) and Josefina Dimalanta visited Myrna Roque (private complainant). Josefina assured Myrna that petitioner was trustworthy and wanted her checks encashed. Petitioner then issued three checks to Myrna: Equitable Bank (EB) Check No. 237936 for ₱40,000.00 (postdated Sept. 30, 1992), EB Check No. 237941 for ₱16,200.00, and Bank of the Philippine Islands (BPI) Check No. 656602 for ₱40,000.00 (postdated Nov. 18, 1992). Procedural History: Upon presentment, the EB checks were dishonored for "Drawn Against Insufficient Funds," and the BPI check was stamped "Account Closed." Myrna, unable to contact petitioner directly, informed Josefina, who assured Myrna not to worry and promised to inform petitioner of the dishonored checks. When no payment was made, Myrna filed a complaint. Three Informations for violation of Batas Pambansa Blg. 22 (BP 22) were filed against petitioner. Petitioner pleaded not guilty, admitting issuance but claiming she merely lent the checks to Josefina, who was to show them to a jeweler as "show money" with the understanding they would not be deposited. Petitioner admitted knowing she had insufficient funds when she issued the checks. The Regional Trial Court (RTC), Branch 130, Caloocan City, found petitioner guilty beyond reasonable doubt and sentenced her to one year imprisonment for each of the three counts, ordering her to indemnify Myrna Roque for the face value of each check. The RTC also cancelled her bail bond. The Court of Appeals (CA) affirmed the RTC decision in toto. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a petition for review on certiorari under Rule 45, raising issues of deprivation of the right to speedy disposition of cases, error in affirming conviction for BP 22 despite incomplete requisites, and error in relying on the complainant's testimony over the accused's corroborated evidence.
Issue(s)
Whether the Court of Appeals violated petitioner’s right to a speedy disposition of cases. Whether the Court of Appeals erred in holding that the prosecution proved petitioner’s guilt beyond reasonable doubt for violation of Batas Pambansa Blg. 22.
Ruling
The Supreme Court denied the petition, affirming the decision of the Court of Appeals which upheld the conviction of the petitioner for violation of Batas Pambansa Blg. 22. The Court found no violation of the right to speedy disposition of cases and ruled that all elements of the offense were sufficiently proven.
Ratio Decidendi
On the issue of speedy disposition of cases: The Court ruled that the petitioner's right to a speedy disposition of cases was not violated. While there was a delay in the resolution of the motion for reconsideration, it was sufficiently explained by the retirement of the ponente and the subsequent reassignment of the case. The Court noted that the new ponente resolved the motion within two weeks of its assignment. The Court reiterated that the concept of speedy disposition is relative and depends on the facts and circumstances of each case, considering factors such as the length of delay, reasons for delay, assertion of the right, and prejudice caused. The delay in this instance was not characterized by vexatious, capricious, or oppressive actions, nor were there unjustified postponements. On the issue of violation of Batas Pambansa Blg. 22: The Court affirmed the findings of the lower courts that all elements of BP 22 were proven beyond reasonable doubt. The elements are: (1) the issuance of a check for value; (2) knowledge of the issuer at the time of issuance that they have insufficient funds or credit with the drawee bank; and (3) the subsequent dishonor of the check by the drawee bank for insufficient funds or credit. The petitioner admitted issuing the checks for value and encashment, and crucially, admitted knowing she had insufficient funds in her Equitable Bank account and that her BPI account was closed. The Court emphasized that BP 22 penalizes the act of issuing a worthless check, which is malum prohibitum, and not the non-payment of an obligation. The purpose of issuance and any alleged collateral agreements are immaterial. The Court also found no merit in the contention that no notice of dishonor was given, as Myrna had no reason to suspect petitioner and naturally turned to Josefina, who promised to inform petitioner. The Court upheld the trial court's findings, noting that the testimony of a single credible witness is sufficient and does not need corroboration.
Main Doctrine
The issuance of a worthless check, knowing at the time of issuance that there are insufficient funds in or credit with the drawee bank for the payment of the check in full upon presentment, and its subsequent dishonor, constitutes a violation of Batas Pambansa Blg. 22, regardless of the purpose for which the check was issued or any alleged agreement that it would not be deposited. The act of issuing a worthless check is considered malum prohibitum.