- Petitioner
- Iluminada Batac
- Respondent
- People
- Citation
- G.R. No. 191622
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Martires, J.
- Decided
- June 6, 2018
Conviction for estafa under Article 315, paragraph 2(d) of the Revised Penal Code for issuing fourteen unfunded postdated checks totaling P103,500.00…
Summary
The Supreme Court affirmed Iluminada Batac's conviction for estafa under Article 315, paragraph 2(d) of the Revised Penal Code but modified her sentence. Batac issued fourteen unfunded postdated checks totaling P103,500.00 to Roger Frias in a rediscounting transaction, representing that the checks were funded. When the checks were dishonored for 'Account Closed,' Batac failed to make good on her obligation despite demand. The Court found all elements of estafa proven: issuance of postdated checks, insufficient funds at time of issuance, and defrauding of the payee. Batac's defense of denial was rejected in favor of positive identification by prosecution witnesses. The Court distinguished estafa from mere B.P. 22 violations, noting estafa requires proof of deceit and damage. Under R.A. No. 10951 amendments, the penalty was reduced to 4 months to 1 year 8 months imprisonment, with restitution and 6% legal interest.