Young v. Court of Appeals

Summary

Jesse Young was convicted of violating BP 22 for issuing a P20,000.00 check without sufficient funds. The Supreme Court affirmed the conviction, ruling that the prima facie presumption of knowledge of insufficient funds was established when petitioner received notice of dishonor and failed to settle within five banking days. The Court clarified that formal demand is not required as an element of the offense under BP 22, distinguishing it from estafa. However, considering petitioner appeared to be a first-time offender, the Court modified the penalty from imprisonment to a fine of P40,000.00, plus civil liability with interest, to enable him to settle his obligations. The decision reinforces that BP 22 violations require proof of knowledge of insufficient funds at time of issuance, which can be established through the statutory presumption.