De Villa v. Court of Appeals
NEW DOCTRINEFacts
The Antecedents: Petitioner Cecilio S. de Villa was charged with violation of Batas Pambansa Bilang 22 (B.P. 22) before the Regional Trial Court of Makati. The charge stemmed from the issuance of a Depositors Trust Company Check No. 3371, dated April 3, 1987, for U.S. $2,500.00 (equivalent to P50,000.00), payable to Roberto Z. Lorayes. The check was dishonored for insufficient funds, and petitioner allegedly failed to pay the amount or make arrangements for payment within five banking days after receiving notice of dishonor. Procedural History: After arraignment and partial presentation of evidence by the private respondent, petitioner moved to dismiss the Information, arguing lack of jurisdiction and that no offense was committed because the check was payable in dollars, thus violating Republic Act No. 529. The Regional Trial Court denied the motion, holding that B.P. 22 covers foreign checks and checks drawn against foreign currency accounts. Petitioner's motion for reconsideration was also denied. Subsequently, petitioner filed a petition for certiorari with the Court of Appeals, which dismissed the petition. A motion for reconsideration of the Court of Appeals' decision was also denied, leading to the present petition. The Petition: This petition for review on certiorari seeks to reverse the Court of Appeals' decision dismissing petitioner's certiorari petition. Petitioner contends that the Regional Trial Court lacks jurisdiction because the check was drawn against a dollar account with a foreign bank, arguing that B.P. 22 does not cover such transactions and that payment in dollars would violate R.A. 529, rendering the obligation void. The core of the petition is whether the Regional Trial Court has jurisdiction over the case involving a dollar-denominated check issued in the Philippines.
Issue(s)
Whether the Regional Trial Court of Makati has jurisdiction over the offense charged, considering the check was drawn against a foreign currency account with a foreign bank, and whether Batas Pambansa Bilang 22 applies to checks drawn against foreign currency accounts. Whether the obligation arising from the issuance of the questioned check is null and void under Republic Act No. 529, thus precluding a violation of Batas Pambansa Bilang 22.
Ruling
The petition is dismissed for lack of merit. The Court of Appeals did not err in dismissing the petition for certiorari.
Ratio Decidendi
On the jurisdiction and applicability of Batas Pambansa Bilang 22 to foreign currency checks: The Supreme Court affirmed the RTC's jurisdiction and the applicability of B.P. Blg. 22. The Court emphasized that jurisdiction is determined by the allegations in the information, which stated the offense was committed in Makati, Metro Manila. Furthermore, the venue for violations of B.P. Blg. 22 is fixed by the place of execution and delivery of the check, which was undisputed to be Makati. Regarding the currency, the Court held that B.P. Blg. 22 does not distinguish the currency involved. The law applies to foreign checks, whether drawn and issued in the Philippines but payable outside, or made payable and dishonored in the Philippines though drawn outside. Crucially, the Court cited legislative deliberations indicating that the law was intended to cover "any check," regardless of currency, including U.S. dollar checks, French francs, Japanese yen, or deutschmarks. The principle of statutory construction that "where the law does not distinguish, courts should not distinguish" was invoked. The Court also noted that checks drawn against current accounts in foreign currency are covered by the law. On the alleged nullity of the obligation under Republic Act No. 529: The Court implicitly rejected the argument that the obligation was null and void. The core of the petition revolved around the applicability of B.P. Blg. 22. By upholding the RTC's jurisdiction and the applicability of the law, the Court indicated that the nature of the currency did not render the check or the obligation void for the purposes of B.P. Blg. 22. The legislative intent, as evidenced by the Batasan records, was to penalize the issuance of bouncing checks regardless of the currency, thereby ensuring the stability and integrity of checks as instruments of commerce within the Philippines, even if denominated in foreign currency. The Court's affirmation of the RTC's denial of the motion to dismiss based on RA 529 indicates that RA 529 does not preclude the application of B.P. Blg. 22 in this context.
Main Doctrine
Batas Pambansa Bilang 22 applies to checks drawn against foreign currency accounts, and jurisdiction for violations thereof is determined by the place of execution and delivery of the check.