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

FACTS

This case consolidates two matters. First, the civil aspect of a criminal case for violation of Batas Pambansa Blg. 22 (B.P. 22). Petitioner Teresita Villaluz purchased a vessel from respondent Reynaldo Anzures in Hong Kong. The purchase price was not paid, and upon their return to Manila, Villaluz issued a postdated check for P2,123,400.00. The check was dishonored upon presentment because Villaluz’s account was already closed. Anzures filed a criminal complaint. The Regional Trial Court (RTC) acquitted Villaluz but held her civilly liable for the value of the check, ordering her to pay Anzures the amount with interest and attorney’s fees. Villaluz appealed this civil liability adjudication to the Court of Appeals (CA).
Second, an ejectment suit involving the other petitioners (Ilagan, the Spouses Taberna, and Llamas). The Anzures spouses purchased from Villaluz a property in Pasay City, which was occupied by her employees (the other petitioners). A condition of the sale was that these employees would vacate by March 31, 1988. They failed to do so. The Metropolitan Trial Court (MTC) ordered their ejectment and payment of rentals. The RTC reversed this, prompting the Anzures spouses to elevate the matter to the CA via a petition for review. The CA consolidated the two cases.

ISSUE

The primary issues were: (1) Whether the CA erred in affirming the RTC’s decision holding Villaluz civilly liable for the value of the dishonored check despite her acquittal in the B.P. 22 case; and (2) Whether the CA erred in setting aside the RTC’s decision and reinstating the MTC’s judgment in the ejectment case.

RULING

The Supreme Court affirmed the CA decision in toto. On the first issue, the Court upheld the civil liability. An acquittal in a criminal case for B.P. 22 does not automatically extinguish the civil liability arising from the issuance of the worthless check. The civil action to recover the civil liability arising from the offense is deemed instituted with the criminal action, unless waived or reserved. The source of the obligation in this case is the contract of sale of the vessel. The dishonored check constitutes evidence of a pre-existing civil obligation to pay the purchase price. The trial court’s finding that the debt was proven by preponderance of evidence in the civil aspect of the case is a factual conclusion accorded great respect. The civil liability persists independently of the criminal culpability.
On the second issue, the Court sustained the CA’s reinstatement of the MTC’s ejectment judgment. The one-year period for filing an unlawful detainer action is counted from the date of the last demand to vacate. The respondents made a written demand on March 11, 1989, and filed the complaint on April 10, 1989, which was well within the one-year period. The RTC therefore erred in dismissing the case for lack of jurisdiction. The CA correctly found that the MTC had jurisdiction over the ejectment suit. The petitioners, as employees whose occupancy was by tolerance of the former owner (Villaluz), became deforciants upon the sale to the Anzures spouses and their subsequent refusal to vacate upon demand.