Cueme v. People

G.R. No. 133325 (June 30, 2000)

Felipa B. Cueme was convicted for 15 counts of dishonored checks, reaffirmed by the Court of Appeals.

Facts:

Felipa B. Cueme, the petitioner, was the General Manager of Mark-Agro Trading Corporation and AMF General Trading Corporation, engaged in trading cacao in Davao and Manila. Helen Simolde, a bank teller at the Bank of the Philippine Islands (BPI), became friends with Cueme and began lending her money. In return, Cueme issued post-dated crossed checks to Simolde, which covered the amounts lent plus interest.

On May 9, 1990, Simolde deposited the checks into her BPI account, but they were dishonored due to insufficient funds. Simolde informed Cueme of the dishonored checks and demanded payment, but Cueme did not respond. Cueme later claimed that she did not borrow money from Simolde and that the checks were not issued for value, asserting that Simolde had procured pre-signed blank checks from her secretary and filled them out herself to show to potential investors.

During the trial, Cueme's secretary, Leonora Gabuan, corroborated Cueme's claims, stating that she had given Simolde the checks only for the purpose of showing them to investors. However, the trial court found Cueme guilty of fifteen violations of Batas Pambansa Blg. 22 (Bouncing Checks Law), sentencing her to six months of imprisonment and fines for each violation, along with an order to pay Simolde the face value of the dishonored checks.

Legal Issues:

  1. Whether Cueme issued the checks to Simolde for value or whether they were merely intended to be shown to potential investors.
  2. Whether the defenses presented by Cueme were sufficient to overturn her conviction under Batas Pambansa Blg. 22.

Arguments:

Petitioner (Cueme):

  • Cueme argued that she did not issue the checks for value, claiming they were intended solely for presentation to potential investors.
  • She contended that the checks were pre-signed and that Simolde filled in the details without her consent.
  • Cueme maintained that the checks were not issued with the intent to defraud, as they were not meant to be encashed.

Respondent (People of the Philippines):

  • The prosecution argued that Cueme issued the checks in exchange for loans from Simolde, which were dishonored due to insufficient funds.
  • They asserted that the mere act of issuing a check that is later dishonored constitutes a violation of Batas Pambansa Blg. 22, regardless of the intent behind the issuance.
  • The prosecution emphasized that the checks were complete on their faces and that Cueme had knowledge of the insufficiency of funds at the time of issuance.

Court's Decision and Legal Reasoning:

The Supreme Court affirmed the decision of the Court of Appeals, which had upheld the trial court's conviction of Cueme. The Court reasoned that the issuance of a worthless check is a violation of public interest, as it undermines the banking system and damages trade and commerce. The Court noted that the offenses under Batas Pambansa Blg. 22 are considered mala prohibita, meaning that the intent behind the act is irrelevant; what matters is whether the law has been violated.

The Court found that the trial court was in a better position to assess the credibility of witnesses and that the testimony of Simolde was credible and consistent. Cueme's claims that the checks were merely for presentation purposes were rejected, as the law does not distinguish between the purpose of the checks. The Court also highlighted that Cueme's admissions in her counter-affidavit contradicted her trial testimony, further undermining her credibility.

The Court modified the penalty in one of the cases to comply with the statutory limits set by Batas Pambansa Blg. 22, but upheld the overall conviction and penalties imposed by the lower courts.

Significant Legal Principles Established:

  1. The issuance of a check that is later dishonored constitutes a violation of Batas Pambansa Blg. 22, regardless of the intent behind the issuance.
  2. In cases involving the credibility of witnesses, appellate courts generally defer to the findings of the trial court.
  3. The law does not differentiate between checks issued for different purposes; the mere act of issuing a check that is dishonored is sufficient for liability under the Bouncing Checks Law.