- Petitioner
- Alvaro
- Respondent
- People
- Citation
- G.R. No. 257059
- Court
- Supreme Court
- Division
- Second Division
- Decided
- January 3, 2022
Summary
This case involves the criminal prosecution of Divina Patacsil Alvaro for two counts of violating BP 22 (Bouncing Checks Law). Alvaro issued two checks totaling P35,000.00 to guarantee a loan from Jay Bautista, but both checks were dishonored for insufficient funds. Despite receiving proper notice, she failed to settle the amounts. All four court levels - from MTCC to Supreme Court - consistently found her guilty beyond reasonable doubt. The Supreme Court emphasized that factual determinations by lower courts are generally not reviewable in Rule 45 petitions, and affirmed the conviction with civil liability plus 6% annual interest from the demand date. The case demonstrates the strict application of BP 22 and the finality of concurrent factual findings across court levels.