G.R. No. 94713 . November 23, 1995.
MANSION BISCUIT CORPORATION, represented by its president, ANG CHO HONG, petitioner, vs. COURT OF APPEALS, TY TECK SUAN substituted by his heirs, ROSENDA TY, ELIZABETH TY KOH, EDWARD TY, EDMUND TY, EDGAR TY, EVELYN T. LIM, EDWIN TY and EDISON TY, and SIY GUI, respondents.

FACTS

Ty Teck Suan, as president of Edward Ty Brothers Corporation, ordered goods from Mansion Biscuit Corporation. As payment, he issued several postdated checks, some co-signed by Siy Gui. Upon presentment, all checks were dishonored for insufficiency of funds. Mansion Biscuit made formal demands for payment, but the obligation remained unmet. Consequently, two criminal cases for violation of Batas Pambansa Blg. 22 (the Bouncing Checks Law) were filed against Ty Teck Suan and Siy Gui.
The trial court granted the accused’s demurrer to evidence and dismissed the criminal cases. The court ruled that the checks were issued merely to guarantee the payment of the obligation, not as actual payment, which was a valid defense at the time of the transactions. The court also ordered the lifting of the earlier writ of attachment on the accused’s properties. Mansion Biscuit appealed the civil aspect of the case to the Court of Appeals, which dismissed the appeal. Hence, this petition.

ISSUE

Whether the acquittal of the accused in the criminal cases for violation of B.P. Blg. 22 extinguished their civil liability arising from the dishonored checks.

RULING

Yes, the acquittal extinguished the civil liability arising from the alleged crime. The Supreme Court affirmed the Court of Appeals’ decision. The legal logic hinges on the nature of the acquittal and the source of the civil liability. The trial court’s order of dismissal was a definitive adjudication that the acts of the accused did not constitute the felony defined under B.P. Blg. 22. The court explicitly found that the checks were issued as a guarantee, not as actual payment for the purchased goods. Since the very basis for criminal liability was absent, no civil liability arising ex delicto (from the crime) could be imposed.
The civil obligation of the accused to pay the value of the checks is not extinguished by the acquittal, but it is a civil liability arising from a separate source—the contract of sale or the law on obligations. This separate civil action must be pursued independently in a civil proceeding, not as a consequence of the criminal case. The Court clarified that the extinction of the penal action does not carry with it the extinction of the civil action unless the extinction proceeds from a declaration in a final judgment that the fact from which the civil might arise did not exist. Here, the acquittal was based precisely on the finding that the essential element of the crime—issuing a check as actual payment—did not exist. Therefore, the civil liability deemed instituted with the criminal case could not be awarded. Petitioner’s remedy is to file a separate civil suit to enforce the contractual obligation.