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NIEVES A. SAGUIGUIT v. PEOPLE

FACTS:

Nieves Saguiguit was charged with eight counts of violation of the Bouncing Checks Law. The charges were filed by Elmer Evangelista, who claimed that Saguiguit had knowingly and unlawfully issued bouncing checks without sufficient funds in the drawee bank. The checks were dishonored due to "ACCOUNT CLOSED" and Saguiguit failed to redeem them despite demand for more than five days. After trial, Saguiguit was found guilty by the Regional Trial Court (RTC), which sentenced her to imprisonment, fines, and ordered her to compensate the complainant. Saguiguit appealed the RTC's decision to the Court of Appeals (CA), but her appeal was dismissed by the CA. Dissatisfied with the CA's decision, Saguiguit sought a review from the Supreme Court, arguing that the Bouncing Checks Law needed reexamination and that the CA's findings were unsupported by evidence. The Supreme Court, however, dismissed her petition, stating that it cannot inquire into the policy behind a statute and that legislative discretion is reserved to Congress. The Court further clarified that its role is to interpret and apply the law, not to amend or repeal it. Additionally, the Court invoked the doctrine of stare decisis, emphasizing the need to adhere to established legal principles, which include the liability of issuers of bouncing checks regardless of intent. The Court concluded that any changes to the law should be directed to Congress for proper amendment.

ISSUES:

  1. Whether or not the rulings that hold issuers of bad checks liable under the Bouncing Checks Law regardless of intent should be modified or abandoned.

  2. Whether or not the agreement surrounding the issuance of a check is relevant to the prosecution and conviction of the petitioner.

  3. Whether or not the Court can grant the petitioner's call for a review of the findings of the facts of the CA.

RULING:

  1. The call to modify or abandon the rulings holding issuers of bad checks liable under the Bouncing Checks Law regardless of intent is denied. Judicial decisions applying or interpreting laws form part of the legal system, and the doctrine of stare decisis requires the Court to adhere to previously established principles of law.

  2. The agreement surrounding the issuance of a check is irrelevant to the prosecution and conviction of the petitioner. The Bouncing Checks Law punishes the act of issuing a worthless check itself, regardless of the purpose or terms and conditions of its issuance.

  3. The Court cannot grant the petitioner's call for a review of the findings of facts of the CA, as the Court is not a trier of facts.

PRINCIPLES:

  • Stare decisis - Judicial decisions applying or interpreting laws shall form part of the legal system, and the Court must adhere to previously established principles of law.

  • Mala prohibita - The Bouncing Checks Law is categorized as a malum prohibitum, punishing the act of making and issuing a worthless check or any check that is dishonored upon presentment for payment.

  • Effects of issuance of a worthless check - The issuance of a worthless check not only harms the payee or holder, but also injures the public and the welfare of society, as it pollutes the channels of trade and commerce and can harm the banking system.