Benjamin T. de Leon, Jr. v. Roqson Industrial Sales

Summary

Petitioner Benjamin T. De Leon, Jr. was criminally acquitted of B.P. 22 violation for issuing a dishonored check worth P436,800.00, but remained civilly liable. The Supreme Court affirmed his civil liability, ruling that while criminal acquittal on reasonable doubt precludes liability ex delicto, petitioner acted as an accommodation party under the Negotiable Instruments Law when he issued his personal check to pay RB Freight's corporate debt for diesel purchases. The Court distinguished between criminal liability (requiring proof beyond reasonable doubt) and civil liability (requiring preponderance of evidence), finding petitioner liable as surety despite not personally benefiting from the transaction. The decision preserved petitioner's right of recourse against the accommodated party, RB Freight, while protecting respondent's right to collect from the accommodation party who issued the personal check.