Alferez v. People

Summary

Jaime Alferez was charged with three counts of violating BP 22 after issuing bouncing checks worth P830,998.40 for construction materials. The lower courts convicted him, but the Supreme Court acquitted him on reasonable doubt. The key issue was whether the prosecution sufficiently proved that Alferez received notice of dishonor. The SC held that registry receipts and return cards must be authenticated to prove receipt, and mere possibility of receipt cannot satisfy the burden of proof beyond reasonable doubt required in criminal cases. The Court emphasized that the presumption of knowledge of insufficient funds under BP 22 only arises after proper notice is received. While Alferez was acquitted criminally, his civil liability for the face value of the checks was affirmed, as acquittal on reasonable doubt does not extinguish civil obligations arising from the same acts.