Ibasco v. CA

G.R. No. 117488 (September 5, 1996)

Facts:

The case involves Santiago Ibasco, who was charged with violating Batas Pambansa Blg. 22, also known as the Bouncing Checks Law. The accusations stemmed from the issuance of three postdated checks to Manuel Trivinio, who, along with his wife, operated an animal feed mill in Gumaca, Quezon. The checks were issued as payment for animal feed supplied to Ibasco, who operated a piggery in Daet, Camarines Norte.

The checks in question were as follows:

1. Check No. 41909 for P15,576.30, postdated February 24, 1984.
2. Check No. 41910 for P17,900.00, postdated March 23, 1984.
3. Check No. 41911 for P18,090.10, postdated April 18, 1984.

Upon presentation, all checks were dishonored due to insufficient funds. Trivinio notified Ibasco of the dishonor, to which Ibasco responded by offering real property as security. However, he failed to settle the amounts owed, leading to the filing of criminal charges against him.

During the trial, Ibasco's defense included a motion to dismiss based on a claim of lack of jurisdiction, arguing that the checks were issued in Daet, Camarines Norte, and not in Gumaca, Quezon, where the case was filed. The trial court denied this motion, affirming that the checks were issued in Gumaca based on witness testimony.

Ibasco was found guilty by the Regional Trial Court of Gumaca, which imposed penalties including imprisonment and fines for each of the three criminal cases. The trial court emphasized that the issuance of the checks constituted a violation of B.P. Blg. 22, regardless of the intent behind the issuance.

Legal Issues:

1. Whether the trial court had jurisdiction over the case given the location of the check issuance.
2. Whether the prosecution proved beyond a reasonable doubt that Ibasco had insufficient funds at the time of the checks' issuance.
3. Whether the checks were issued as a guarantee for a pre-existing obligation, which would exempt Ibasco from criminal liability under B.P. Blg. 22.

Arguments:

• Petitioner (Ibasco):

  • Argued that the trial court lacked jurisdiction because the checks were issued in Daet, Camarines Norte.
  • Contended that the prosecution failed to prove his guilt beyond a reasonable doubt, particularly regarding his knowledge of insufficient funds.
  • Claimed that the checks were issued as a guarantee for a pre-existing obligation, which should not constitute a violation of B.P. Blg. 22.

• Respondents (People of the Philippines):

  • Asserted that jurisdiction was proper as the checks were delivered in Gumaca, Quezon, where the case was filed.
  • Maintained that the dishonor of the checks created a presumption of knowledge regarding insufficient funds.
  • Argued that B.P. Blg. 22 applies regardless of whether the checks were issued as payment or as a guarantee, emphasizing the legislative intent to prevent the issuance of worthless checks.

Court's Decision and Legal Reasoning:

The Supreme Court upheld the decisions of the lower courts, affirming Ibasco's conviction. The Court reasoned that:

1. Jurisdiction: The trial court had jurisdiction because the checks were delivered in Gumaca, Quezon, as established by witness testimony. The Court noted that the delivery of the checks was a critical factor in determining jurisdiction.

2. Knowledge of Insufficient Funds: The Court reiterated that the mere issuance of a dishonored check creates a presumption that the drawer knew of the insufficiency of funds. This presumption is sufficient to establish the element of knowledge required for a violation of B.P. Blg. 22.

3. Nature of the Offense: The Court distinguished between the nature of the offense under B.P. Blg. 22 and the crime of estafa. It emphasized that the law penalizes the act of issuing a check that is dishonored, regardless of the underlying transaction or the intent behind the issuance. The Court rejected Ibasco's defense that the checks were issued merely as guarantees, stating that the checks were issued in payment of a debt and thus constituted a violation of the law.

Significant Legal Principles Established:

• The jurisdiction for cases under B.P. Blg. 22 is determined by the place of delivery of the checks, not merely where they were issued.
• The issuance of a dishonored check creates a presumption of knowledge regarding insufficient funds, which is a critical element of the offense.
• B.P. Blg. 22 applies to all instances of dishonored checks, regardless of whether they were issued as payment or as guarantees for obligations.