Benjamin Evangelista v. Screenex

Summary

Evangelista was charged with BP 22 violation for issuing two dishonored checks totaling P1.5 million as security for a 1991 loan from Screenex, Inc. While acquitted of criminal charges due to lack of proof of knowledge of insufficient funds, lower courts held him civilly liable. The Supreme Court reversed, ruling that the civil action had prescribed. Since the checks were undated and issued in 1991, but not deposited until 2005 (over 10 years later), the 10-year prescriptive period under Article 1144 of the Civil Code had elapsed. Additionally, under Article 1249 and the Negotiable Instruments Law, the creditor's unreasonable delay in presenting the checks for over 10 years discharged the debtor's obligation by operation of law. This case establishes important precedent on prescription of actions based on negotiable instruments and the discharge of obligations through creditor's unreasonable delay in presentment.