Emilia Lim vs. Mindanao Wines & Liquor, G.R. No. 175851, 4 July 2012.

DEL CASTILLO, J.

FACTS: Despite her acquittal from the charges of violation of BP 22 (Bouncing Checks
Law), the lower courts still found petitioner Emilia Lim civilly liable and ordered her to pay
the value of the bounced checks. In her Petition for Review on Certiorari, Emilia prays for the
reversal and setting aside of the said rulings, contending since her acquittal was based on
insufficiency of evidence, it should then follow that the civil aspect of the criminal cases filed
against her be likewise dismissed.

ISSUE: Whether an acquittal from a crime necessarily mean absolution from civil
liability.

RULING: Notwithstanding her acquittal, Emilia is civilly liable. In any case, even if the
Court treats the subject dismissal as one based on insufficiency of evidence as Emilia wants to
put it, the same is still tantamount to a dismissal based on reasonable doubt. As may be recalled,
the MTCC dismissed the criminal cases because one essential element of BP 22 was
missing, i.e., the fact of the banks dishonor. The evidence was insufficient to prove said
element of the crime as no proof of dishonor of the checks was presented by the
prosecution. This, however, only means that the trial court cannot convict Emilia of the crime
since the prosecution failed to prove her guilt beyond reasonable doubt, the quantum of
evidence required in criminal cases. Conversely, the lack of such proof of dishonor does not
mean that Emilia has no existing debt with Mindanao Wines, a civil aspect which is proven by
another quantum of evidence, a mere preponderance of evidence.