Medalla v. Laxa

Summary

This Supreme Court case involves criminal prosecution under BP 22 for issuing a bouncing check. Petitioner Medalla issued a P742,000.00 check to respondent Laxa as loan payment, but it bounced due to account closure. Medalla claimed the check was only a guarantee and that subsequent novation through partial payments extinguished his criminal liability. The Supreme Court denied his petition, emphasizing that BP 22 punishes the issuance of worthless checks regardless of subsequent payments, and that novation cannot extinguish criminal liability after an Information has been filed. The Court also noted that the petition improperly raised only factual questions inappropriate for Rule 45 certiorari review. The case affirms that BP 22 violations are offenses against public order, not property, and that criminal liability persists despite civil settlements.