People v. Saguiguit
REITERATIONFacts
The Antecedents: Petitioner Nieves A. Saguiguit was charged in eight (8) separate informations with violations of Batas Pambansa (B.P.) Blg. 22, the Bouncing Checks Law. The informations uniformly alleged that the petitioner willfully, unlawfully, and feloniously drew and issued Traders Royal Bank checks to complainant Elmer Evangelista, knowing she had insufficient funds, and that these checks were dishonored for the reason "ACCOUNT CLOSED." Despite demand, she failed to redeem the checks, causing damage to the complainant. Procedural History: The Regional Trial Court (RTC) of Angeles City, in Criminal Case Nos. 94-03-226 to 94-03-233, found the petitioner guilty of all eight counts of violating B.P. Blg. 22. She was sentenced to one (1) year imprisonment and a fine for each case, with subsidiary imprisonment in case of insolvency, and ordered to indemnify the complainant. The petitioner appealed this decision to the Court of Appeals (CA). The CA, in its Decision dated June 28, 2000, affirmed the RTC's conviction. The Petition: Petitioner seeks review of the CA's decision under Rule 45 of the Rules of Court. She argues for a reexamination and modification, if not abandonment, of existing jurisprudence holding that the mere issuance of a dishonored check constitutes a violation of B.P. Blg. 22, regardless of the parties' intent. She contends that the lawmaking body did not intend for the issuance of a worthless check to be an automatic criminal offense without proof of intent to commit the prohibited act and that the check should have been issued for value. Petitioner also requests a review of the CA's factual findings, asserting they are unsupported by evidence and differ from the RTC's findings.
Issue(s)
Whether the petitioner's conviction for violation of B.P. Blg. 22 is proper, considering her assertion regarding the intent of the parties and the purpose of the check issuance, given that B.P. Blg. 22 classifies the offense as mala prohibitum. Whether the Supreme Court should reexamine findings of fact, considering its role as not a trier of facts, and whether the established fact of issuing bouncing checks constitutes a violation of B.P. Blg. 22.
Ruling
The petition is devoid of merit. The Supreme Court affirmed the conviction of the petitioner but modified the penalty imposed by the lower courts. Petitioner Nieves Saguiguit was sentenced to pay a fine equivalent to double the amount of each check, with subsidiary imprisonment in case of insolvency, and to indemnify the private complainant with the total amount of the checks plus interest.
Ratio Decidendi
On the issue of intent and purpose of check issuance: The Court reiterated that Batas Pambansa Blg. 22 classifies the offense as mala prohibitum, where the gravamen is the act of issuing a worthless check. The law was designed to curb the pernicious practice of issuing checks without sufficient funds, which harms public interest and the banking system. The Court emphasized that the issuance of a worthless check, whether as an accommodation or not, is covered by B.P. 22, and the agreement surrounding its issuance is irrelevant to the prosecution and conviction. This adherence to established jurisprudence is grounded in the doctrine of stare decisis, ensuring stability in the legal system. The Court cannot amend or repeal a law, as such matters fall within the legislative domain, and judicial interpretation is confined to applying the law as written. On the issue of reexamining findings of fact: The Supreme Court affirmed its basic rule that it is not a trier of facts. It reiterated that its jurisdiction is limited to reviewing questions of law. Even assuming the petitioner's version of facts were true, the issuance of eight (8) bouncing checks that went into circulation remains an established fact, constituting a violation of B.P. Blg. 22 and causing injury to public interest. The Court cannot deviate from its established role in the judicial hierarchy to re-evaluate factual determinations made by lower courts, especially when such re-evaluation is not warranted by the circumstances of the case.
Main Doctrine
The issuance of a worthless check, regardless of the intent or purpose of the parties, is punishable under Batas Pambansa Blg. 22 as it is a crime classified as mala prohibitum, where the gravamen of the offense is the act of making and issuing a worthless check that is dishonored upon presentment. The Supreme Court affirmed its adherence to the doctrine of stare decisis in cases involving BP Blg. 22, emphasizing that the law punishes the act of issuing a bouncing check itself, not the purpose for which it was issued. However, the penalty imposed may be modified by imposing a fine double the amount of the check, in line with Administrative Circulars No. 12-2000 and 13-2001, especially for first-time offenders without indications of habitual delinquency.