GR 144054; (June, 2006) (Digest)
G.R. No. 144054 ; June 30, 2006
NIEVES A. SAGUIGUIT, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
Petitioner Nieves Saguiguit was convicted by the Regional Trial Court of Angeles City on eight counts of violating Batas Pambansa Blg. 22 (the Bouncing Checks Law). The separate informations uniformly alleged that she issued checks to Elmer Evangelista, which were subsequently dishonored by the drawee bank for reason “ACCOUNT CLOSED.” Despite notice and demand, she failed to make the checks good within five days. The trial court sentenced her to imprisonment and fines for each count, a decision affirmed by the Court of Appeals.
On appeal to the Supreme Court, Saguiguit sought a reexamination of jurisprudence, arguing that the mere issuance of a subsequently dishonored check should not ipso facto constitute a criminal offense absent proof of intent to commit fraud. She contended that the check must be issued to apply on account or for value, and that the appellate court’s factual findings were erroneous.
ISSUE
Whether the Supreme Court can reexamine the interpretation of B.P. Blg. 22 to require proof of criminal intent for conviction, and whether it can review the factual findings of the Court of Appeals.
RULING
The Supreme Court denied the petition. On the first issue, the Court held that it cannot delve into the policy or wisdom behind B.P. Blg. 22, as such matters are within the exclusive domain of the legislature under the doctrine of separation of powers. The Court’s role is limited to interpreting and applying the law as written. The law itself, as consistently interpreted in jurisprudence, establishes a malum prohibitum offense where criminal intent is not an element; the act of issuing a worthless check, knowing at the time of issuance that one does not have sufficient funds, is punishable. Petitioner’s plea for a requirement of intent is essentially a call for a legislative amendment, which must be addressed to Congress.
On the second issue, the Court reiterated that in a petition for review under Rule 45, only questions of law may be raised. Factual findings of the Court of Appeals, especially when affirming the trial court, are generally conclusive and binding. No compelling reason was shown to warrant an exception to this rule. However, in line with recent judicial policy aimed at avoiding excessive imprisonment for non-habitual offenders in B.P. Blg. 22 cases, the penalty was modified. The imprisonment was deleted, and petitioner was sentenced to pay a fine equivalent to double the amount of each check, plus indemnification of the private complainant with legal interest.