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Mary Ann Rodriguez vs. Hon. Thelma A. Ponferrada, et al.

MARY ANN RODRIGUEZ, Petitioner, versus Hon. THELMA A. PONFERRADA, in Her Official Capacity as Presiding Judge of the Regional Trial Court of Quezon City, Branch 104; PEOPLE OF THE PHILIPPINES; and GLADYS NOCOM, Respondents.

G.R. Nos. 155531-34 | 2005-07-29

THIRD DIVISION

D E C I S I O N 

PANGANIBAN, J.: 

Settled is the rule that the single act of issuing a bouncing check may give rise to two distinct criminal offenses: estafa and violation of Batas Pambansa Bilang 22 (BP 22). The Rules of Court allow the offended party to intervene via a private prosecutor in each of these two penal proceedings. However, the recovery of the single civil liability arising from the single act of issuing a bouncing check in 
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* On official leave. 

either criminal case bars the recovery of the same civil liability in the other criminal action. While the law allows two...