Teodoro A. Reyes v. Ettore Rossi

Summary

The Supreme Court ruled that a civil action for rescission of a contract of sale does not constitute a prejudicial question warranting suspension of criminal proceedings for Bouncing Checks Law violations. Reyes purchased dredging equipment through conditional sale, issuing post-dated checks as payment. When checks were dishonored, Rossi filed criminal charges while Reyes sought contract rescission claiming misrepresentation. The Court held that BP 22 violations are complete upon check issuance when the contract was still valid, and rescission proceedings cannot retroactively absolve criminal liability. The resolution of contract validity does not determine guilt or innocence in the criminal case, as both proceedings address distinct legal issues and can proceed independently. This decision clarifies the limited scope of prejudicial questions in criminal law.