King v. People

Summary

Betty King was prosecuted for 11 counts of violating BP 22 (Bouncing Checks Law) for issuing checks that were subsequently dishonored for 'Account Closed.' The RTC and Court of Appeals convicted her, finding all elements of the crime proven. However, the Supreme Court reversed and acquitted her, holding that the prosecution failed to prove beyond reasonable doubt that she received notice of dishonor. The Court emphasized that under Section 2 of BP 22, the prima facie presumption of knowledge of insufficient funds only arises when the accused receives notice of dishonor and fails to pay within five banking days. Since the registered demand letter was returned to sender unclaimed and no other proof of notice was presented, the presumption could not arise. The decision reinforces that all elements of criminal offenses must be proven beyond reasonable doubt and that penal statutes are construed strictly against the State.