People v. Mejia
REITERATIONFacts
The Antecedents: Rodolfo M. Bernardo, Jr. (Bernardo) requested Atty. Ismael F. Mejia (petitioner) to pay his real estate taxes. Bernardo delivered a blank check to petitioner, who filled it with P27,700.00, making himself the payee, and encashed it. Petitioner later explained that P10,000.00 was a loan for his wife's hospitalization, and Bernardo agreed to this. Petitioner then borrowed an additional P40,000.00 from Bernardo for his wife's medication, making the total loan P50,000.00. To secure this loan, petitioner issued Philippine National Bank (PNB) Check No. 156919 dated May 15, 1985, for P50,000.00, payable to Bernardo, and a Promissory Note due on or before May 15, 1985. Procedural History: When the check became due, petitioner requested Bernardo not to encash it until July 15, 1985, but failed to pay on that date and subsequently asked for further deferment. On October 8, 1985, Bernardo deposited the check, but it was dishonored by PNB due to petitioner's closed account. Bernardo sent a demand letter, which petitioner refused to pay. Bernardo then filed an Information for violation of Batas Pambansa Blg. 22 (B.P. 22) against petitioner. The Regional Trial Court (RTC), Branch 197, Pasig City, found petitioner guilty beyond reasonable doubt and sentenced him to pay a fine of P50,000.00 and to pay Bernardo P50,000.00 with interest and P10,000.00 for attorney's fees. The Court of Appeals (CA) affirmed the RTC decision with modification, deleting the award for attorney's fees. Petitioner's motions for reconsideration were denied. The Petition: Petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Civil Procedure, assailing the CA's Decision and Resolutions.
Issue(s)
Whether the Court of Appeals erred in affirming the trial court's decision convicting petitioner for violation of Batas Pambansa Blg. 22, considering the elements of the offense and the irrelevance of the check's purpose.
Ruling
The petition is DENIED. The challenged Decision of the Court of Appeals and its twin Resolutions in CA-G.R. CR No. 15066 are AFFIRMED. Costs against petitioner.
Ratio Decidendi
On the Issue of Conviction for Violation of B.P. 22: The Court affirmed the conviction of the petitioner for violation of Batas Pambansa Blg. 22. The prosecution successfully proved the essential elements of the offense: (1) the making, drawing, and issuance of a check for account or value; (2) the issuer's knowledge at the time of issue that there were no sufficient funds or credit with the drawee bank for the check's payment; and (3) the subsequent dishonor of the check by the drawee bank for insufficiency of funds or credit. The trial court found that the petitioner issued the check as a guarantee for a loan, knowing that his account with PNB had been closed. This knowledge was established by the fact that the check was dishonored for the reason "ACCOUNT CLOSED" when presented for payment. The petitioner was duly notified of the dishonor and failed to make good the check despite demand. The Court reiterated the settled rule that factual findings of the trial court, affirmed by the Court of Appeals, are entitled to great weight and respect. Furthermore, the Court emphasized that the gravamen of the offense under B.P. 22 is the issuance of a bad check, and the purpose for which the check was issued, or any agreement surrounding its issuance, is irrelevant to the prosecution and conviction. This is because the law, B.P. 22, was intended to make the mere act of issuing a worthless check malum prohibitum, thereby preserving faith in the stability and commercial value of checks as currency substitutes. The Court also noted that while it sympathizes with the petitioner's misfortunes, courts are not forums for pleading sympathy; their duty is to apply the law.
Main Doctrine
The gravamen of the offense under Batas Pambansa Blg. 22 is the issuance of a worthless check. The purpose for which the check was issued, or any agreement surrounding its issuance, is irrelevant to the prosecution and conviction for violation of B.P. 22, as the law intends to make the mere act of issuing a worthless check malum prohibitum.