G.R. No. 106214 September 5, 1997
TERESITA VILLALUZ, CHIT ILAGAN, Spouses ADOR and TESS TABERNA and MARIO LLAMAS, petitioners, vs. THE HONORABLE COURT OF APPEALS and SPOUSES REYNALDO AND ZENAIDA ANZURES, respondents.

FACTS

This petition involves two consolidated cases. The first (CA G.R. No. 28780) concerns the civil aspect of a criminal case for violation of Batas Pambansa Blg. 22. Private respondent Reynaldo Anzures sold a vessel to petitioner Teresita Villaluz in Hong Kong. The purchase price was not paid upon delivery, with the agreement that payment would be made in Manila. Villaluz failed to pay. After demands, Villaluz issued a postdated Producers Bank check for P2,123,400.00 to Anzures. The check was dishonored because Villaluz’s account was already closed. Villaluz was acquitted of the criminal charge but was held civilly liable by the trial court and ordered to pay Anzures the check amount with interest and attorney’s fees. Villaluz appealed this civil liability.
The second case (CA G.R. S.P. No. 20055) is an ejectment suit. The Anzures spouses bought a lot and building from Villaluz. A condition of the sale was that Villaluz’s employees (petitioners Ilagan, Spouses Taberna, and Llamas) would vacate the premises by March 31, 1988. They failed to vacate. The Metropolitan Trial Court ordered ejectment, but the Regional Trial Court reversed this. The Court of Appeals, upon the Anzures’ petition, reinstated the MTC’s ejectment order.
The Court of Appeals consolidated the cases and affirmed the trial court’s ruling on Villaluz’s civil liability in the B.P. 22 case and set aside the RTC’s decision in the ejectment suit, ordering the other petitioners to vacate the property.

ISSUE

1. Whether petitioner Teresita Villaluz is civilly liable to private respondents for the value of the dishonored check.
2. Whether the civil case in the B.P. 22 matter constitutes a prejudicial question to the ejectment case.
3. Whether the one-year period for filing the ejectment suit had prescribed.

RULING

1. Yes, petitioner Teresita Villaluz is civilly liable. The Supreme Court affirmed the factual findings of the lower courts, which are conclusive. The trial court was convinced the check represented Villaluz’s total obligation to Anzures for the unpaid vessel. The Court of Appeals found it undeniable that Villaluz bought the vessel, did not pay, and issued the check for the amount of her indebtedness. Despite her acquittal, she may still be held civilly liable under Section 2, Rule 120 of the Rules of Court, as the act from which civil liability arises existed. Her claim that the checks were issued without consideration is untenable under the Negotiable Instruments Law, which presumes consideration for every instrument.
2. No, the civil case in the B.P. 22 matter does not constitute a prejudicial question to the ejectment case. A prejudicial question must be one arising in a case the resolution of which is a logical antecedent of the issue involved in the ejectment case. The issue in the ejectment case is possession, while the B.P. 22 civil case involves a monetary obligation from a sale. They are distinct and separate.
3. No, the one-year period for filing the ejectment suit had not prescribed. The cause of action accrued on April 1, 1988, when the petitioners failed to vacate as agreed. The complaint was filed on April 28, 1989, which is within the one-year period from the accrual of the cause of action.
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals in toto.