G.R. No. 190834 , November 26, 2014
ARIEL T. LIM, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner Ariel T. Lim issued two Bank of Commerce checks, each for ₱100,000.00, payable to CASH, as a campaign donation to Willie Castor. Castor used these checks to pay for printing materials from private complainant Magna B. Badiee. Castor later instructed petitioner to issue a “Stop Payment” order because the materials were delivered late. The checks were dishonored due to the stop payment order, and a bank officer testified they were also drawn against insufficient funds (DAIF). Badiee sent demand letters. After more than a month from receipt of the demand letters and after receiving a subpoena from the Office of the Prosecutor, petitioner issued a replacement check for ₱200,000.00, which Badiee encashed. Nevertheless, six months after this payment, two Informations for violation of B.P. Blg. 22 were filed against petitioner. The Metropolitan Trial Court (MeTC) convicted him. The Regional Trial Court (RTC) modified the decision, acquitting him in one case for lack of jurisdiction but affirming his conviction in the other. The Court of Appeals (CA) affirmed the RTC judgment. The CA found the precedent in Griffith v. Court of Appeals inapplicable, noting petitioner’s payment was made only after receiving a subpoena and that the checks were personal, not corporate.

ISSUE

Whether petitioner should be acquitted of violation of B.P. Blg. 22 because he had fully paid the amount of the dishonored checks before the Informations were filed in court.

RULING

Yes. The Supreme Court reversed the CA decision and acquitted petitioner. The Court found the ruling in Griffith v. Court of Appeals applicable. In Griffith, the accused was acquitted because the value of the bounced checks had been paid two years before the filing of the Information. The Court rejected the CA’s distinction based on the checks being personal and the timing of payment (after a subpoena). It noted that in Griffith, payment was not voluntary but from a foreclosure, yet acquittal was still granted. The key similarity is that payment was made before the court filing. The Court reiterated the principle from Griffith that penal laws should not be applied mechanically; when the reason for the law ceases, the law ceases. Since petitioner voluntarily paid the full amount six months before the Informations were filed, holding him criminally liable is no longer tenable. The Court distinguished this from estafa cases, where payment does not extinguish criminal liability. Therefore, petitioner is acquitted.