Sps. Carolina v. Sps. Laureano

Summary

Respondent spouses borrowed money from petitioners at 5% daily interest and issued postdated checks for repayment. When multiple B.P. Blg. 22 criminal cases were filed against Purita Suarez, respondents sought suspension claiming the unconscionable interest rate rendered the checks void as contra bonos mores, creating a prejudicial question. The RTC and Court of Appeals agreed and issued preliminary injunction stopping the criminal proceedings. The Supreme Court reversed, holding that no prejudicial question exists because B.P. Blg. 22 punishes the mere issuance of bouncing checks regardless of the underlying transaction's validity. The Court emphasized that B.P. Blg. 22 is malum prohibitum - the purpose or conditions of check issuance are irrelevant to criminal liability. The Court also found respondents guilty of forum shopping and lifted the preliminary injunction, ordering the criminal cases to proceed.