Yap v. Cabales

Summary

Jesse Y. Yap issued postdated checks to purchase real estate properties. When the checks bounced due to account closure, the holders filed civil collection cases and criminal cases for violation of Batas Pambansa Bilang 22 were subsequently filed. Yap sought to suspend the criminal proceedings claiming the civil cases posed a prejudicial question. The Supreme Court denied the petition, ruling that no prejudicial question exists because the resolution of whether check holders are entitled to collect damages would not determine guilt or innocence in the B.P. Blg. 22 cases. The Court emphasized that B.P. Blg. 22 punishes the mere act of issuing worthless checks regardless of the purpose or consideration, making it a malum prohibitum offense. The decision clarifies the doctrine of prejudicial questions and reinforces that criminal and civil cases can proceed independently when resolution of one does not determine the outcome of the other.