Macalalag v. People

Summary

Theresa Macalalag was prosecuted for violation of Batas Pambansa Blg. 22 after issuing two bouncing checks as security for loans totaling P200,000. The Supreme Court affirmed her conviction on one count, rejecting arguments that partial payments before check presentation or payments during trial proceedings could exempt her from criminal liability. The Court applied the Medel doctrine to reduce unconscionable interest rates from 10% and 6% monthly to 12% annually, finding that payments made covered the first loan but not the second. The decision emphasized that BP 22 violation is malum prohibitum, requiring no criminal intent, and that only full payment during the statutory grace period could have prevented liability. The case clarifies the intersection of usury law principles with bouncing check prosecutions and the limited defenses available under BP 22.