G.R. No. 107898 December 19, 1995
Manuel Lim and Rosita Lim, petitioners, vs. Court of Appeals and People of the Philippines, respondents.

FACTS

Petitioners Manuel and Rosita Lim, spouses and corporate officers of Rigi Bilt Industries, Inc., were charged with three counts of estafa under Article 315(2)(d) of the Revised Penal Code and seven counts of violation of Batas Pambansa Blg. 22 (Bouncing Checks Law). The charges stemmed from their purchase of steel products from Linton Commercial Company, Inc., for which they issued several Solidbank checks as payment. Upon presentment, all checks were dishonored by the drawee bank for the reason “Payment Stopped” and/or “Drawn Against Insufficient Funds.” Despite demand, petitioners failed to make good the checks.
The trial court convicted petitioners on all counts. On appeal, the Court of Appeals acquitted them of estafa but affirmed their conviction for violating B.P. Blg. 22. The appellate court found that the checks were not issued simultaneously with the receipt of the goods but weeks later, thus negating the element of deceit for estafa. However, it held all elements of B.P. Blg. 22 were present. Petitioners sought review, arguing they had sufficient funds and stopped payment due to alleged non-conformity of the delivered goods to specifications.

ISSUE

Whether the Court of Appeals erred in affirming petitioners’ conviction for violation of Batas Pambansa Blg. 22.

RULING

The Supreme Court affirmed the conviction. The legal logic is clear: the offense under B.P. Blg. 22 is committed upon the issuance of a check that is subsequently dishonored, provided the issuer knew at the time of issuance that he did not have sufficient funds or credit with the drawee bank. The law punishes the act of making and issuing a worthless check. Petitioners’ defense of having sufficient funds based on a ledger balance is unavailing. The bank’s certification of dishonor for “Insufficient Funds” is prima facie evidence of knowledge of insufficiency. The fact that some checks were also dishonored for “Payment Stopped” does not negate liability; the stop-payment order, issued after the checks were drawn, does not erase the violation that occurred at the moment of issuance with knowledge of insufficiency. The alleged reason for stopping payment—non-conformity of goods—pertains to the civil aspect of the transaction and is not a valid defense to the criminal act of issuing a bouncing check. The Court also upheld the territorial jurisdiction of the Malabon RTC, as the checks were issued and delivered there.