WOCD – Raffy Brodeth and Rolan B. Onal vs.

People of the Philippines and Abraham Villegas

G. R. No. 197849, November 29, 2017

Facts:

On August 16, 2001, there were two charges against the petitioners involving dishonoured
checks for reason “Drawn against insufficient funds.” On August 31 and September 5 in 1999, the
accused draw and issue 2 checks from Metrobank to Vill Integrated Transport Corporation, represented
by Abraham Villegas, in the amount of P140, 000.00 and P123, 600.00 respectively. Despite receipt of
notice of such dishonours, said accused, failed to pay VITC the amount of the check or make
arrangements for full payment of the same within five banking days after receiving said notice.

The petitioners argued they had arranged with a certain Cristina Villegas that the checks will be
paid in cash but they have no receipts to prove their claims. The Metropolitan Trial Court found
petitioners guilty beyond reasonable doubt for the offense charged on July 2, 2008, and on the 29th, the
petitioners timely filed a notice of appeal, and the case was forwarded to the Regional Trial Court for
further proceedings but the CA denied petitioners' appeal. It emphasized that the gravamen of the
offense charges is the issuance of a bouncing check regardless of the purpose why it was issued. The fact
that the checks were drawn by a corporation cannot exculpate petitions from the charge against them.
Further, the CA maintained that the MeTC had jurisdiction to try the case because the complaint
affidavit categorically stated that the checks were issued in Manila. The petitioners filed the instant
petition after the CA promulgated the assailed resolution denying their motion for reconsideration.

Issue:

1. Whether or not the Metropolitan Trial Court have the jurisdiction over the case which affirmed
reliance on hearsay evidence about where the check was issued.

Ruling:

The prosecution failed to prove that the subject checks were issued in Manila nor was any evidence
shown that these were either drawn, delivered, or deposited in Manila, therefore, the court granted the
petition. The May 17, 2011 Decision and the July 20, 2011 Resolution of the Court of Appeals in CA-G.R.
CR No. 33104 are REVERSED and SET ASIDE on the ground of lack of jurisdiction on the part of the
Metropolitan Trial Court, Branch 30, Manila. Criminal Case Nos. 371104-CR & 371105-CR are DISMISSED
without prejudice.