ORIEL MAGNO, vs. HONORABLE COURT OF APPEALS and PEOPLE OF THE PHILIPPINES.
- G.R. Number: G.R. No. 96132
- Promulgated: 1992-06-26
- Ponente: Paras, J.
Doctrine
Violations of BP Blg. 22 are mala prohibita; in such cases the sole inquiry is whether the law was violated and proof of criminal intent is not necessary for conviction.
The material question in prosecutions under BP Blg. 22 is whether postdated checks were issued 'to apply on account or for value.'
Facts
This is an appeal by certiorari under Rule 45 from the Court of Appeals' decision affirming the RTC conviction of the accused-petitioner for violations of Batas Pambansa Blg. 22 in four criminal cases (Q-35693 to Q-35696).
The Solicitor General summarized the antecedent facts and circumstances of the four counts in its Comment before the Court of Appeals.
The trial court found the accused violated BP Blg. 22, a mala prohibita statute, and held that proof of criminal intent is not necessary for conviction under such law.
The central factual issue concerned the reason the petitioner drew postdated checks—whether they were drawn 'to apply on account or for value' under Section 1 of BP Blg. 22.
Issues
Whether the petitioner violated Batas Pambansa Blg. 22 by issuing postdated checks not intended 'to apply on account or for value.'
Ruling
The Court reversed the appealed decision and acquitted the accused-petitioner of the crime charged.
Keywords
G.R. No. 96132, appeal by certiorari, Rule 45 of the Revised Rules of Court, Batas Pambansa Blg. 22, BP Blg. 22, warranty deposit, leasing agreement, postdated check, short term loan, Regional Trial Court, Court of Appeals, offense of violations of B.P. Blg. 22, imprisonment for one year, legal keywords, legal doctrines, statutory references, piercing the corporate veil, mortgagee in good faith, finance, equipment