GR 215118; (June, 2019) (Digest)
G.R. No. 215118 June 19, 2019
MARIA NYMPHA MANDAGAN, Petitioner, vs. JOSE M. VALERO CORPORATION, Respondent.
FACTS
Jose M. Valero Corporation (JMVC) extended an accommodation to Maria Nympha Mandagan, allowing her to use its corporate name for a car loan. Under a lease-to-own arrangement, JMVC gave Mandagan possession of a vehicle, and she issued 34 postdated checks for her monthly amortizations. Eleven checks were subsequently dishonored. JMVC’s treasury head and general account supervisor communicated the dishonors to Mandagan and demanded payment. JMVC’s counsel later sent a formal demand letter. After preliminary investigation, Mandagan was charged with eight counts of violating B.P. 22. The Metropolitan Trial Court convicted her. On appeal, the Regional Trial Court acquitted her on reasonable doubt but sustained her civil liability.
The Court of Appeals annulled the RTC Decision and reinstated the MeTC conviction. The CA held that the prosecution proved all elements of B.P. 22, particularly that Mandagan received a notice of dishonor. It ruled that the RTC erred in finding that the prosecution failed to prove receipt of the demand letter, noting that Mandagan admitted its genuineness in the pre-trial order and that her subsequent actions constituted an acknowledgment of her obligation and the dishonor.
ISSUE
Whether the Court of Appeals erred in reversing the RTC’s acquittal of Mandagan for violation of B.P. 22.
RULING
Yes. The Supreme Court reversed the CA and reinstated the RTC’s acquittal. The Court emphasized that an appeal of a judgment of acquittal places the accused in double jeopardy and is prohibited unless there is a grave abuse of discretion amounting to lack or excess of jurisdiction by the trial court. The RTC’s acquittal was based on its finding that the prosecution failed to prove beyond reasonable doubt that Mandagan received a notice of dishonor, a requisite element under B.P. 22. The RTC meticulously evaluated the evidence, concluding that the pre-trial admission pertained only to the letter’s existence, not its receipt, and that the prosecution’s other evidence was insufficient. This was an evaluation of the evidence’s weight and credibility, well within the RTC’s discretion. No whimsical, arbitrary, or capricious exercise of power was shown; hence, no grave abuse of discretion existed to warrant an exception to double jeopardy. The CA therefore erred in reviewing and overturning the acquittal on its merits. However, the civil liability for the value of the dishonored checks, as affirmed by the RTC, stands.