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The People of the Philippines vs. Teresa Jalandoni

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The People of the Philippines vs. Teresa Jalandoni

Case Title and Citation

The People of the Philippines, plaintiff-appellee, vs. Teresa Jalandoni, accused-appellant.
G.R. No. L-57555, May 30, 1983
Supreme Court - Second Division
Ponente: Abad Santos, J.

Facts

  • On July 30, 1962, H. M. Jalandoni and Teresa Jalandoni opened a joint current account with the Bank of the Philippine Islands (BPI), Plaza Cervantes Branch, account No. 2274-1. After H. M. Jalandoni’s death, on November 22, 1973, Maria Teresa J. Macapagal (appellant’s daughter) replaced him as co-owner.
  • Appellant also maintained a current account with Rizal Commercial Banking Corporation (RCBC), Greenhills Branch, account No. 6-06061.
  • On September 8, 1976, appellant drew three RCBC checks totaling P750,000 payable to cash and deposited them in her BPI account No. 2274-1. Prior to or simultaneously with the deposit, she issued 25 checks aggregating P745,980 which BPI honored on her assurance that the RCBC checks were funded. The bank returned eleven other checks to her upon request.
  • On September 9, 1976, appellant drew three RCBC checks totaling P650,000 payable to cash and deposited them in her BPI account. Prior to or simultaneously with the deposit, she issued 26 checks totaling P639,700 which BPI honored on her assurance that the RCBC checks were funded. The bank returned eleven other checks to her upon request.
  • On September 10, 1976, appellant drew three RCBC checks totaling P750,000 payable to cash and deposited them in her BPI account. Prior to or simultaneously with the deposit, she issued 22 checks totaling P656,100 which BPI honored on her assurance that the RCBC checks were funded. The bank returned six other checks to her upon request.
  • Of the RCBC checks deposited, all except RCBC No. 2424530 (P200,000) were later dishonored for lack of sufficient funds when presented to RCBC Greenhills.
  • Appellant admitted issuing nine RCBC personal checks with a total face value of P2,150,000; one was honored (P200,000); checks drawn against those deposits aggregated P2,041,780; and the alleged damage was P1,391,780 (as stated in the information).
  • Trial court convicted appellant of estafa under Article 315(2)(a) and sentenced her to reclusion perpetua, ordered indemnification to BPI in P1,600,000, and costs.
  • Appellant claimed she had been granted overdraft (OD) or drawn against uncollected deposit (DAUD) privileges by BPI; bank managers Garcia and Ignacio testified regarding the bank’s practice of honoring checks against uncollected deposits for long-standing, creditworthy customers and presented bank statements and records (exhibits) showing recurrent overdrafts and check-clearing entries.
  • Appellant mortgaged a lot (with her son’s authority) for P250,000 applied to one dishonored check and gave jewelry worth P300,000 to the BPI president as evidence of effort to pay; manager Garcia later retired and was not prosecuted.

Issues

  1. Did Teresa Jalandoni act with intent to defraud the Bank of the Philippine Islands by issuing and depositing RCBC checks she knew were unfunded, thereby committing estafa under Article 315(2)(a)?

Ruling

  1. No - The Court held that the prosecution failed to prove beyond reasonable doubt that appellant acted with criminal intent to defraud; the evidence showed bank practices and accommodations (OD/DAUD privileges) and other circumstances that raised reasonable doubt.

Reasoning / Ratio Decidendi

  • The information charged estafa under Article 315(2)(a), which requires proof of deceit or fraudulent intent causing damage.
  • The Court examined the bank records and testimony of bank managers (Manuel L. Garcia and Eriberto M. Ignacio) showing that BPI routinely honored checks drawn against uncollected deposits for customers of long standing and good credit standing. Testimony explained the bank’s practice of treating certain deposits as “JE” (journal entry/check deposits) and posting checks resulting sometimes in interim overdrafts pending clearing.
  • The Court found these banking practices and the fact that appellant had been previously accorded OD/DAUD privileges materially weakened any inference of deliberate fraud. The managers’ testimony and bank statements (exhibits) demonstrated a course of dealing that made it reasonable for branch staff to honor checks on the basis of deposited but uncollected checks.
  • The Court noted that the branch manager who allowed the accommodations (Garcia) was not charged; his retirement and absence as a co-accused suggested the bank’s participation or at least acquiescence in the practice, diminishing the attribution of sole criminal intent to appellant.
  • Circumstantial facts also weighed against imputing fraud: one deposited RCBC check was honored, appellant caused payments to reduce the alleged loss (mortgage and P250,000 loan applied; jewelry worth P300,000 given to bank president), and funds drawn were issued in favor of third parties rather than being taken personally; these factors supported reasonable doubt as to defendant’s intent to defraud.
  • Given the prosecution’s failure to exclude reasonable hypotheses consistent with innocence, the Court held guilt was not proven beyond reasonable doubt and acquitted appellant.

Doctrine / Legal Principle

  • Criminal fraud (estafa) requires proof of criminal intent beyond reasonable doubt; practices and accommodations by a banking institution that create a reasonable belief of coverage can negate such intent.
  • Proof of venue, act, and damage alone is insufficient; intent must be established clearly.
  • Evidence of restitution, collateralization, and accommodations by bank officers may raise reasonable doubt as to fraudulent intent.

Disposition

  • The appealed judgment convicting Teresa Jalandoni of estafa is set aside.
  • A new judgment is entered acquitting Teresa Jalandoni of the charge.
  • No costs.

Concurring / Dissenting Opinions

  • Justices Aquino, Concepcion, Jr., Guerrero, De Castro and Escolin, JJ., concurred in the judgment.
  • Makasiar, J., dissented, arguing conviction should be affirmed on the ground that the evidence showed active false pretenses and fraudulent representations by the accused to induce the bank to honor checks.

Significance / Notes

  • Reinforces that criminal liability for estafa hinges on proof of fraudulent intent beyond reasonable doubt, not solely on the fact of dishonored checks.
  • Highlights the relevance of the bank’s internal practices (OD/DAUD) and the conduct of bank officers in assessing criminal culpability of depositors.
  • Illustrates that restitution efforts and disposition of collateral may be considered in evaluating intent and damage.
  • Serves as precedent that failure to charge implicated bank officers may bear on the credibility of a prosecution that imputes sole criminality to a depositor.
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