Josephine B. Zabarte v. Franliza "Lizette" Belarmino

Summary

This case involves the intersection of civil and criminal liability where creditor Zabarte filed both a civil collection case for P394,792.47 based on a promissory note and 10 criminal B.P. 22 cases for bounced checks totaling P1,904,448.62 against debtor Belarmino for the same loan obligation. The Supreme Court ultimately affirmed dismissal of the civil case due to litis pendentia, establishing that when B.P. 22 criminal cases are filed, the corresponding civil action is deemed automatically included under Rule 111 of the Rules of Criminal Procedure and SC Circular 57-97, preventing separate civil proceedings for the same obligation. The decision reinforces the policy of preventing multiplicity of suits and using courts as debt collectors, while noting that the underlying B.P. 22 cases had already attained finality with a finding that the debtor's obligations were extinguished by payment.