Lim v. People · G.R. 190834

Petitioner: Lim
Respondent: People
Citation: G.R. No. 190834
Court: Supreme Court
Division: Third Division
Ponente: Peralta, J.
Decided: November 26, 2014

Summary

Petitioner Ariel T. Lim was prosecuted for violation of B.P. Blg. 22 after issuing two bounced checks totaling P200,000 as campaign donation. The checks were dishonored due to stop payment orders, but would have bounced for insufficient funds. Despite paying the full amount via replacement check six months before criminal charges were filed, lower courts convicted him. The Supreme Court reversed, applying the Griffith doctrine that criminal liability under B.P. Blg. 22 is extinguished when payment is made before filing of Information. The Court emphasized that penal laws should not be applied mechanically and must serve their intended purpose of protecting banking system integrity. Since petitioner made restitution before formal charges, continuing prosecution would not serve justice but subvert it. The decision reinforces that early payment demonstrates good faith and satisfies the law's protective purpose.

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Bouncing Checks Law (B.P. 22)

By the Intellegal Editorial Board · November 26, 2014

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