SAN MIGUEL CORPORATION v. HELEN T. KALALO

FACTS:

San Miguel Corporation (SMC) filed a petition assailing the decisions of the Court of Appeals (CA), the Regional Trial Court (RTC), and the Metropolitan Trial Court (MeTC). The MeTC acquitted respondent Helen T. Kalalo of a violation of the Bouncing Checks Law but ordered her to pay SMC the amount of ?71,009 for unpaid goods. Kalalo had a credit overdraft arrangement with SMC, where she would issue two checks before the delivery of beer products. She would issue one blank check and another check to be filled up with the corresponding amount of the delivered goods. The actual amount due to SMC would be computed at the end of the week and written on the blank check, which Kalalo would fund. However, as her business grew, it became difficult for Kalalo to keep track of the transactions, and she requested regular statements of account from SMC, but they failed to comply. Subsequently, SMC required Kalalo to issue several postdated checks without informing her of the breakdown of the balance. Kalalo, after making payments and returning empty beer bottles and cases, discovered that she still owed a substantial amount to SMC. She then ordered her bank to stop payment on the last seven checks she had issued to SMC, amounting to ?921,215. Instead of updating her account, SMC sent her a demand letter. In response, Kalalo's counsel submitted a compromise proposal, but SMC did not accept it. SMC filed a complaint against Kalalo for violating the Bouncing Checks Law. During trial, SMC finally updated Kalalo's account and determined that the net balance owed was only ?71,009. The MeTC acquitted Kalalo but ordered her to pay SMC the said amount. SMC appealed the civil aspect to the RTC, but it affirmed the MeTC's decision. The CA also dismissed the appeal, prompting SMC to file a Rule 45 Petition before the Supreme Court.

ISSUES:

  1. Whether or not the respondent is civilly liable to petitioner for the amount of ?71,009 representing the value of unpaid goods.

RULING:

  1. The court ruled that the respondent is civilly liable to the petitioner for the amount of ?71,009 representing the value of unpaid goods.

PRINCIPLES:

  • The right against double jeopardy prevents filing an appeal of the criminal aspect of a case if the accused has already been acquitted.

  • A person can be acquitted of a violation of Batas Pambansa Bilang 22 but still be held civilly liable for the amount of the bounced checks.

  • The statement of account is crucial in determining the actual amount owed to the complainant in a criminal case for violation of Batas Pambansa Bilang 22.

  • When a compromise agreement is not accepted by the complainant, the accused can withdraw it and deny its validity.