Bouncing Checks Law (B.P. 22)

Answer Summary

Batas Pambansa Blg. 22 (BP 22) penalizes the mere act of making or drawing and issuing a check that is subsequently dishonored for insufficiency of funds or credit. The offense is malum prohibitum (a prohibited act), meaning criminal intent is not an essential element. The law punishes two distinct acts: (1) issuing a check knowing at the time of issue that there are insufficient funds, which is subsequently dishonored; and (2) having sufficient funds when issuing but failing to maintain sufficient funds or credit to cover the check if presented within 90 days from the date of the check, resulting in dishonor.

The governing statute is Batas Pambansa Blg. 22 (1979). The elements of the first offense are: (a) the making, drawing or issuance of any check to apply on account or for value; (b) knowledge of the maker/drawer/issuer that at the time of issue he does not have sufficient funds or credit for payment in full upon presentment; and (c) subsequent dishonor of the check by the drawee bank for insufficiency of funds or credit, or that it would have been dishonored for the same reason had not the drawer, without any valid cause, ordered the bank to stop payment. The controlling case for these elements is Macalalag v. People, G.R. No. 164358 (20 December 2006, J. Callejo, Sr.), consistently cited in subsequent rulings.

Under Section 2 of BP 22, a prima facie presumption of knowledge of insufficient funds arises when a check is dishonored for insufficient funds upon presentment within 90 days from its date, and the drawer fails to pay the amount or make arrangements for full payment within five banking days after receiving notice of dishonor. The Supreme Court has consistently held that proof of actual receipt of notice is indispensable to trigger this presumption. Failure to prove receipt results in acquittal, as in King v. People, G.R. No. 131540 (2 December 1999), Yu Oh v. Court of Appeals, G.R. No. 125297 (6 June 2003), and Alferez v. People, G.R. No. 182301 (31 January 2011).

The penalty under Section 1 of BP 22 is imprisonment of not less than 30 days but not more than one year, or a fine of not less than but not more than double the amount of the check (with a fine ceiling of Two Hundred Thousand Pesos), or both, at the discretion of the court. Supreme Court Administrative Circular No. 12-2000 establishes a rule of preference for the imposition of a fine alone over imprisonment, especially for first-time offenders, as further clarified by Administrative Circular No. 13-2001. However, imprisonment remains an available penalty; the court may, in its sound discretion, determine whether a fine alone suffices or imprisonment is warranted under the circumstances. If only a fine is imposed and the accused is unable to pay, subsidiary imprisonment under the Revised Penal Code applies suppletorily. Jao Yu v. People, G.R. No. 134172 (20 September 2004) authoritatively resolves this.

Civil liability for the amount of the check is deemed instituted with the criminal action under Section 1(b) of Rule 111 of the Rules of Court, and no separate civil action may be reserved or filed independently once a BP 22 criminal case is initiated. Even if the accused is acquitted on reasonable doubt in the criminal case, civil liability for the face value of the dishonored check may still be imposed upon proof by preponderance of evidence. Vicente v. People, G.R. No. 261347 (11 January 2023) and Milanes v. Cosmos Bottling Corp., G.R. No. 232967 (5 December 2018) illustrate this principle.

Recognized defenses include: (1) full payment of the check before the filing of the Information, as held in Lim v. People, G.R. No. 190834 (26 November 2014); (2) absence of receipt of notice of dishonor, which prevents the presumption of knowledge from arising; (3) payment or arrangement for payment within the five-day grace period under Section 2; (4) the check was not issued for account or for value (e.g., mere evidence of an investment or guarantee, as in Magno v. Court of Appeals and Idos v. Court of Appeals, referenced in Young v. Court of Appeals, G.R. No. 140425); and (5) prescription of the offense, which is four years under Act No. 3326, interrupted by the filing of the complaint with the prosecutor. Defenses like lack of consideration, partial payment, novation, and the payee's knowledge of insufficient funds are generally not accepted.

Based on comprehensive database and web research, no rulings from 2024-2026 were found on this topic. The most recent authorities are Leofando v. People, G.R. No. 229367 (4 October 2023), Villarama v. People, G.R. No. 253639 (31 August 2022), Pineda-Clarino v. People, G.R. No. 259491 (25 July 2022), and Vicente v. People, G.R. No. 261347 (11 January 2023).

Section I — Issue Overview

1. What acts are penalized under BP 22 and what are the elements of the offense, including recognized defenses?
   This is the foundational question. Practitioners must know the exact statutory elements to evaluate the strength of a case and to frame charges or defenses. The distinction between a check issued for value (covered) and one given as security or evidence of an investment (not covered) can be decisive.

2. What is the effect of the prima facie presumption of knowledge of insufficient funds arising from dishonor and failure to pay within five banking days?
   The presumption shifts the evidentiary burden, but its application hinges on proof that the drawer actually received notice of dishonor. Understanding the strict evidentiary requirements for notice is critical for both prosecution and defense strategies.

3. What are the penalties under BP 22 and how do Administrative Circulars No. 12-2000 and 13-2001 bear on the preference for a fine over imprisonment?
   Courts now have a clear policy guideline favoring fines, especially for first-time offenders, but imprisonment and subsidiary imprisonment remain valid. Counsel must know when to argue for a fine-only penalty and how to structure the plea or sentencing mitigation.

4. How does civil liability for the amount of the check relate to the criminal action for BP 22 violation?
   The criminal case automatically includes the civil claim. A separate civil suit is prohibited. However, civil liability may survive criminal acquittal if the underlying act of issuing the dishonored check is proven by preponderance of evidence. This interplay affects case strategy and settlement considerations.

Section II — Legal Analysis

Issue 1: What acts are penalized under BP 22 and what are the elements of the offense; what are the recognized defenses?

Applicable Laws & Issuances

Batas Pambansa Blg. 22 (1979), Section 1 penalizes:

Any person who makes or draws and issues any check to apply on account or for value, knowing at the time of issue that he does not have sufficient funds in or credit with the drawee bank for the payment of such check in full upon its presentment, which check is subsequently dishonored by the drawee bank for insufficiency of funds or credit or would have been dishonored for the same reason had not the drawer, without any valid reason, ordered the bank to stop payment…

The second paragraph of Section 1 punishes a person who has sufficient funds when making and issuing a check but subsequently fails to maintain sufficient funds or credit to cover the full amount if presented within 90 days from the date on the check, and the check is dishonored. Section 1 further provides that where the check is drawn by a corporation, company or entity, the person who actually signed the check in behalf of such drawer is liable.

Case Law Analysis

Macalalag v. People, G.R. No. 164358 — 20 December 2006 (J. Callejo, Sr.) Focus of Dispute: Whether partial payments made before the check's presentment constitute a defense to BP 22. Facts: Petitioner issued two P100,000 checks as security for loans. Both were dishonored (account closed). She had paid a total of ₱156,000 before presentment and an additional ₱199,837.98 during trial. The trial court convicted on one check, acquitted on the other. Disposition: Conviction affirmed on one check. Ratio Decidendi: Partial payment is not a defense; only full payment at time of presentment or within the five-day grace period can exonerate. The Court set out the elements: (1) making, drawing, issuing any check to apply on account or for value; (2) knowledge of insufficient funds at the time of issuance; (3) subsequent dishonor for insufficiency. The offense is malum prohibitum. Evidence Evaluated: The prior payments were insufficient to cover the second check's face value; subsequent payments during trial only affect civil liability, not criminal. Precedential Status: Good law, consistently followed.

Young v. Court of Appeals, G.R. No. 140425 — 10 March 2005 (J. , First Division) Focus of Dispute: Whether informing the payee of insufficient funds is a defense; whether conviction is proper without prior formal demand. Facts: Petitioner issued a check for cash that was dishonored; he ordered a stop payment without valid reason. He claimed he told the payee he lacked funds. Disposition: Conviction affirmed; penalty reduced to fine. Ratio Decidendi: The defense that the drawer notified the payee of insufficient funds applies only when the check was not issued for value (citing Magno v. CA and Idos v. CA where checks were mere evidence of an investment or guarantee). Here, the check was issued for value. The elements were: (1) making/drawing/issuing a check for account or for value; (2) knowledge of insufficient funds; (3) dishonor. Precedential Status: Distinguishes between checks for value and those given as security only; remains authoritative.

Lim v. People, G.R. No. 190834 — 26 November 2014 Focus of Dispute: Whether payment before the filing of the Information extinguishes criminal liability. Facts: Petitioner issued two bounced checks worth ₱200,000 as a campaign donation. He paid the full amount via replacement check six months before the criminal Information was filed. Disposition: Acquitted. Ratio Decidendi: Applying the Griffith doctrine, criminal liability under BP 22 is extinguished when full payment is made before the filing of the Information in court. The purpose of the law — to protect the banking system — is served when restitution is made early. Precedential Status: Landmark on the extinguishment defense.

Doctrinal Synthesis

The crime under BP 22 has three essential elements: (1) the accused makes, draws or issues any check to apply on account or for value; (2) the accused knows at the time of issuance that he or she does not have sufficient funds or credit with the drawee bank for payment in full upon presentment; and (3) the check is subsequently dishonored by the drawee bank for insufficiency of funds or credit, or would have been so dishonored but for an unjustified stop-payment order. The gravamen is the issuance of a worthless check — it is a malum prohibitum offense; intent to defraud is not required.

Recognized defenses include:

• Full payment before the Information is filed (Lim v. People).
• Absence of notice of dishonor or lack of proof of receipt, which precludes the presumption of knowledge (discussed in Issue 2).
• Payment or arrangement for payment within five banking days after receipt of notice of dishonor (Section 2, BP 22).
• The check was not issued for account or for value — e.g., it was given as a mere guarantee or evidence of a partnership interest, not as a payment instrument.
• Prescription: The offense prescribes in four years under Act No. 3326, interrupted by the filing of the complaint with the prosecutor's office.
• Lack of knowledge of issuance: If the accused can show they did not sign or authorize the check, or had no participation.

Defenses that do not lie:

• Lack or failure of consideration.
• Partial payment before filing of Information (only full payment extinguishes liability).
• Novation or subsequent agreement.
• Payee's knowledge of insufficient funds.
• The check was intended as security or collateral, if it was still issued “for value” (i.e., to apply on account or to obtain something).

Issue 2: What is the effect of the prima facie presumption of knowledge of insufficient funds arising from dishonor and failure to pay within five banking days?

Applicable Laws & Issuances

Batas Pambansa Blg. 22, Section 2:

The making, drawing and issuance of a check payment of which is refused by the drawee because of insufficient funds in or credit with such bank, when presented within ninety (90) days from the date of the check, shall be prima facie evidence of knowledge of such insufficiency of funds or credit unless such maker or drawer pays the holder thereof the amount due thereon, or makes arrangements for payment in full by the drawee of such check within five (5) banking days after receiving notice that such check has not been paid by the drawee.

Case Law Analysis

King v. People, G.R. No. 131540 — 2 December 1999 (J. Panganiban) Focus of Dispute: Whether receipt of notice of dishonor must be proven beyond reasonable doubt to trigger the prima facie presumption. Facts: Petitioner issued 11 post-dated checks; upon presentment they were dishonored (Account Closed). Demand letter was sent by registered mail but returned to sender. Disposition: Acquitted. Ratio Decidendi: “Section 2 creates a prima facie presumption... However, in order to create the prima facie presumption that the issuer knew of the insufficiency of funds, it must be shown that he or she received a notice of dishonor and, within five banking days thereafter, failed to satisfy the amount of the check or make arrangement for its payment.” The absence of a notice of dishonor deprives the accused of the opportunity to avert prosecution, violating procedural due process. The demand letter’s return to sender proved non-receipt. Precedential Status: Foundational case on the notice requirement; repeatedly cited.

Yu Oh v. Court of Appeals, G.R. No. 125297 — 6 June 2003 Focus of Dispute: Whether notice of dishonor is required even when the check is dishonored for “Account Closed.” Facts: Petitioner issued post-dated checks as part of a compromise agreement; checks were dishonored for Account Closed. Prosecution did not prove she received any notice. Disposition: Acquitted. Ratio Decidendi: The Court held that even with Account Closed checks, written notice of dishonor is mandatory to give the drawer the five-day grace period. The presumption under Section 2 cannot arise without proof of actual receipt. Precedential Status: Consistent with King.

Alferez v. People, G.R. No. 182301 — 31 January 2011 Focus of Dispute: Whether unauthenticated registry receipts suffice to prove receipt of notice. Facts: Petitioner was convicted for three BP 22 counts; prosecution relied on registry return cards that were not authenticated. Disposition: Acquitted. Ratio Decidendi: Registry receipts and return cards must be properly authenticated to prove receipt. The mere possibility of receipt does not satisfy proof beyond reasonable doubt. The Court emphasized that the presumption of knowledge only arises after proper notice is received. Precedential Status: Strengthened the evidentiary requirement for proving notice.

Doctrinal Synthesis

The prima facie presumption of knowledge of insufficient funds under Section 2 of BP 22 operates as follows: if the prosecution proves beyond reasonable doubt that (a) the check was dishonored for insufficiency of funds, (b) it was presented within 90 days from its date, and (c) the drawer received a notice of dishonor and failed to pay or make arrangements within five banking days, then knowledge is presumed. The burden shifts to the accused to rebut this presumption. However, if the prosecution fails to prove actual receipt of notice, the presumption never arises. The prosecution must authenticate registry return receipts or present the person who mailed or served the notice. Written notice is required; verbal demands are insufficient (Domagsang). Thus, the notice requirement is both an element of the offense and a procedural due process safeguard. Failure to prove receipt leads to acquittal.

Issue 3: What are the penalties (imprisonment and/or fine) and how do Supreme Court Administrative Circulars No. 12-2000 and No. 13-2001 bear on the preference for a fine over imprisonment?

Applicable Laws & Issuances

Batas Pambansa Blg. 22, Section 1, provides:

shall be punished by imprisonment of not less than thirty days but not more than one (1) year or by a fine of not less than but not more than double the amount of the check which fine shall in no case exceed Two Hundred Thousand Pesos, or both such fine and imprisonment at the discretion of the court.

Supreme Court Administrative Circular No. 12-2000 (November 21, 2000) set forth the policy that courts should prefer the imposition of a fine over imprisonment for BP 22 violations, following the rulings in Eduardo Vaca v. Court of Appeals and Rosa Lim v. People. It directed all courts and judges to “take note of the foregoing policy.”

Supreme Court Administrative Circular No. 13-2001 (February 14, 2001) clarified AC 12-2000:

• AC 12-2000 does not remove imprisonment as an alternative penalty; it establishes a rule of preference.
• Judges may, in the exercise of sound discretion, determine whether a fine alone best serves the interests of justice, or whether forbearing imprisonment would depreciate the seriousness of the offense, work violence on the social order, or be contrary to the imperatives of justice.
• Where circumstances indicate good faith or a clear mistake of fact without negligence, a fine alone should be considered the more appropriate penalty.
• If only a fine is imposed and the accused cannot pay, there is no legal obstacle to applying the Revised Penal Code provisions on subsidiary imprisonment.

Case Law Analysis

Jao Yu v. People, G.R. No. 134172 — 20 September 2004 Focus of Dispute: Whether subsidiary imprisonment can be imposed under BP 22 for non-payment of fine. Facts: Petitioner was convicted of 19 counts, fined, and ordered to suffer subsidiary imprisonment if unable to pay. Disposition: Petition denied; subsidiary imprisonment upheld. Ratio Decidendi: “The above provisions on subsidiary imprisonment can be applied suppletorily to Batas Pambansa Blg. 22 pursuant to Article 10 of the Revised Penal Code.” Administrative Circular No. 13-2001 clarifies that if only a fine is imposed and the accused cannot pay, there is no legal obstacle to applying RPC provisions on subsidiary imprisonment. Precedential Status: Authoritative on subsidiary imprisonment.

Pineda-Clarino v. People, G.R. No. 259491 — 25 July 2022 Focus of Dispute: Whether a lump-sum fine exceeding ₱200,000 per count is permissible. Facts: Seven BP 22 counts with checks totaling ₱735,000; lower court imposed a lump fine of ₱755,000. Disposition: Modified; fine fixed at face value per check, with subsidiary imprisonment in case of insolvency. Ratio Decidendi: The fine ceiling of ₱200,000 applies per count; imposing a lump sum that breaches this cap is error. The proper penalty is a fine per check, not exceeding double the amount but with a cap of ₱200,000. Precedential Status: Reaffirms strict application of statutory fine limits.

Doctrinal Synthesis

The penalty structure under BP 22 is: 30 days to 1 year imprisonment, or a fine of not less than the check amount, not more than double, with an absolute cap of ₱200,000, or both. Under AC 12-2000 and 13-2001, the Supreme Court has mandated a rule of preference: courts should impose a fine alone, particularly for first-time offenders and when good faith or no negligence is present. Imprisonment is not removed; it remains an alternative. The judge’s discretion is guided by the circular. If the accused fails to pay the fine, subsidiary imprisonment under Articles 38-39 of the RPC applies suppletorily. The fine is imposed separately for each count, not as a lump sum, and must respect the per-check ceiling.

Issue 4: How does civil liability for the amount of the check relate to the criminal action for a BP 22 violation?

Applicable Laws & Issuances

Rule 111, Section 1(b) of the Rules of Criminal Procedure provides that “the criminal action for violation of Batas Pambansa Blg. 22 shall be deemed to include the corresponding civil action. No reservation to file such civil action separately shall be allowed.” This was enacted to prevent multiplicity of suits and the use of criminal courts as mere collection devices.

Civil Code of the Philippines, Article 29, allows a civil action for damages for the same act or omission even if the accused is acquitted on the ground that guilt has not been proved beyond reasonable doubt, requiring only a preponderance of evidence. Article 31 permits independent civil actions based on obligations not arising from the act or omission complained of as a felony, which may proceed independently of the criminal case.

Case Law Analysis

Vicente v. People, G.R. No. 261347 — 11 January 2023 Focus of Dispute: Whether civil liability survives criminal acquittal under BP 22. Facts: Petitioner was acquitted criminally on two bounced checks. The CA affirmed civil liability. Disposition: Petition denied; civil liability affirmed. Ratio Decidendi: Criminal acquittal does not automatically extinguish civil liability when the underlying act of issuing the checks exists. Civil liability requires only preponderance of evidence. Interest at 6% per annum was applied. Precedential Status: Current doctrine on survival of civil liability.

Simon Heirs v. Chan, G.R. No. 157547 — 23 February 2011 Focus of Dispute: Whether a separate civil action can be filed to recover the value of a bounced check when a BP 22 criminal case is pending. Facts: After a BP 22 case was filed, the complainant filed a separate collection case. Disposition: The separate civil action was dismissed. Ratio Decidendi: Under Rule 111, Section 1(b), the criminal action for BP 22 shall be deemed to include the corresponding civil action. No separate civil action may be filed or reserved. The policy is to declog dockets and prevent forum shopping. Precedential Status: Doctrinal; bars independent civil suits for the same bounced check.

Doctrinal Synthesis

The civil liability for the face value of a dishonored check is automatically included in the criminal action for BP 22. No reservation is allowed; once the criminal case is filed, the civil claim is part of the case. If the accused is convicted, the court must award the civil indemnity (the face value) plus interest as computed under Nacar v. Gallery Frames. If the accused is acquitted on reasonable doubt, the court may still impose civil liability if the evidence preponderates that the act of issuing the dishonored check occurred. The civil liability is distinct and independent of the criminal penalty. However, a separate civil action for collection cannot be maintained when a BP 22 criminal case is already pending; the proper forum is within the criminal proceeding. If the criminal case is dismissed or the accused dies during appeal, the civil liability may survive and be enforced against the estate (Payumo v. Meneses).

Recent Developments

No legislative amendments to BP 22 have been enacted. However, there have been legislative proposals, such as House Bill No. 2741, seeking to decriminalize the issuance of bouncing checks by making the penalties purely civil or by reducing imprisonment, but none have become law. Case law from 2018-2023 continues to reaffirm existing doctrines, with the Supreme Court emphasizing strict proof of notice of dishonor and the proper computation of fines and interest. The most recent rulings (Leofando 2023, Vicente 2023, Pineda-Clarino 2022) show no deviation from established precedent. No Supreme Court rulings from 2024-2026 were identified through database or web research.

Section III — Action Plan & Evidence Guide

Recommended Strategy:
In prosecuting or defending a BP 22 case, the most critical evidentiary issue is typically the notice of dishonor. For the prosecution, ensure that the demand letter, mailing receipts, and registry return card are properly authenticated and that the signatory or postal custodian is presented as a witness. For the defense, scrutinize whether the prosecution's proof of receipt meets the beyond-reasonable-doubt standard. On the penalty, prepare to argue for a fine-only penalty under AC 12-2000 if the accused is a first-time offender and can show good faith. On civil liability, be aware that even if acquitted, the accused may remain civically liable; settlement of the civil aspect before trial could be beneficial.

Action Steps:

1. Preserve and authenticate all documents related to the check and notice — Gather the original dishonored check with stamped reason, the demand letter, registry receipt, return card, and any correspondence. Arrange for the postal official or private courier to testify.
2. File the criminal complaint promptly — The offense prescribes in four years from the date of dishonor. Ensure the complaint is filed with the Office of the Prosecutor within this period to interrupt prescription.
3. Evaluate defense of full payment before Information — If the drawer paid the full amount before the criminal Information was filed in court, move for dismissal based on the Griffith doctrine (Lim v. People).
4. Assert civil claim within the criminal case — No separate civil action is allowed. Ensure the Information includes the civil claim for the face value of the check. During trial, present evidence of the debt and the check’s value.
5. At sentencing, argue for fine only — Cite AC 12-2000 and 13-2001, establish the accused’s first-offender status and good faith. Prepare documentation of partial payments or settlement offers.

Evidence Checklist:

• Dishonored original check — proves drawing and dishonor (elements 1,3); obtain from complainant or bank
• Bank return slip / stamped “DAIF” or “Account Closed” — proves dishonor reason; from drawee bank
• Demand letter with proof of mailing (registry receipt) — proves notice of dishonor; from complainant’s records
• Registry return card / courier tracking — proves actual receipt by accused; secure from post office/courier with authentication
• Affidavit of service or testimony of person who mailed/served — authenticates notice; crucial for presumption
• Bank statement or certification — shows account balance at time of issuance and presentment; from drawee bank
• Testimony of complainant or authorized representative — establishes the transaction and consideration; at trial
• Payment records — if defense asserts payment before Information; from drawer’s records

⚠️ This is AI-generated legal research for reference only. It does not constitute legal advice. Consult a licensed Philippine attorney before making important legal decisions.

References

Legislation & Regulatory Issuances

• Bouncing Checks Law (Batas Pambansa Blg. 22)
• Clarification of Administrative Circular No. 12-2000 on the Penalty for Violation of Batas Pambansa Blg. 22, Otherwise Known as the Bouncing Checks Law (Supreme Court Administrative Circular No. 13-01)
• Penalty for Violation of B.P. Blg. 22 (Supreme Court Administrative Circular No. 12-00)
• Civil Code of the Philippines (Republic Act No. 386)

Case Law

• Macalalag v. People, G.R. No. 164358 (20 December 2006)
• King v. People, G.R. No. 131540 (2 December 1999)
• Young v. Court of Appeals, G.R. No. 140425 (10 March 2005)
• Jao Yu v. People, G.R. No. 134172 (20 September 2004)
• Ongson v. People, G.R. No. 156169 (12 August 2005)
• Lim v. People, G.R. No. 190834 (26 November 2014)
• Ocampo v. People, G.R. No. 251254 (28 July 2020)
• Danao v. People, G.R. No. 218030 (22 July 2015)
• Alvaro v. People, G.R. No. 257059 (3 January 2022)
• Yu Oh v. Court of Appeals, G.R. No. 125297 (6 June 2003)
• Alferez v. People, G.R. No. 182301 (31 January 2011)
• Resterio v. People, G.R. No. 177438 (24 September 2012)
• Domagsang v. Court of Appeals, G.R. No. 139292 (5 December 2000)
• Suarez v. People, G.R. No. 172573 (19 June 2008)
• Dela Cruz v. People, G.R. No. 163494 (3 August 2016)
• Pineda-Clarino v. People, G.R. No. 259491 (25 July 2022)
• Wong v. Court of Appeals, G.R. No. 117857 (2 February 2001)
• Lagman v. People, G.R. No. 146238 (7 December 2001)
• Sumbilla v. Matrix Finance, G.R. No. 197582 (29 June 2015)
• Vicente v. People, G.R. No. 261347 (11 January 2023)
• Milanes v. Cosmos Bottling, G.R. No. 232967 (5 December 2018)
• De Leon, Jr. v. Roqson Industrial Sales, Inc., G.R. No. 234329 (23 November 2021)
• Simon Heirs v. Chan, G.R. No. 157547 (23 February 2011)
• Hyatt Industrial Mfg. Corp. v. Asia Dynamic Electrix Corp., G.R. No. 163597 (29 July 2005)
• Buenaflor v. Federated Distributors, Inc., G.R. Nos. 240187-88 (28 March 2022)