Lozano v. Martinez

Summary

This landmark En Banc decision consolidated multiple constitutional challenges to Batas Pambansa Bilang 22 (Bouncing Check Law). Petitioners from various criminal cases argued BP 22 violated constitutional prohibitions against imprisonment for debt, impaired freedom of contract, denied equal protection, and improperly delegated legislative powers. The Supreme Court unanimously upheld BP 22's constitutionality, ruling that the law punishes the act of issuing worthless checks as malum prohibitum, not debt non-payment. The Court emphasized the law's purpose of protecting public interest and banking system integrity through valid exercise of police power. The decision distinguished between criminalizing the harmful practice of circulating worthless checks versus imprisoning debtors for contractual obligations, establishing that BP 22 addresses public welfare concerns rather than debt collection. This ruling resolved significant legal uncertainty surrounding the bouncing check law's validity.