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HYATT INDUSTRIAL MANUFACTURING CORP. v. ASIA DYNAMIC ELECTRIX CORP.

This case has been cited 5 times or more.

	GR No. 157547 2011-02-23	SIMON v. CHAN BERSAMIN, J.
The reasons for issuing Circular 57-97 were amply explained in Hyatt Industrial Manufacturing Corporation v. Asia Dynamic Electrix Corporation,[23] thus: xxx
	GR No. 174238 2009-07-07	ANITA CHENG v. SPS. WILLIAM SY AND TESSIE SY NACHURA, J.
Indeed, under the present revised Rules, the criminal action for violation of BP Blg. 22 includes the corresponding civil action to recover the amount of the checks. It should be stressed, this policy is intended to discourage the separate filing of the civil action. In fact, the Rules even prohibits the reservation of a separate civil action, i.e., one can no longer file a separate civil case after the criminal complaint is filed in court. The only instance when separate proceedings are allowed is when the civil action is filed ahead of the criminal case. Even then, the Rules encourages the consolidation of the civil and criminal cases. Thus, where petitioner's rights may be fully adjudicated in the proceedings before the court trying the BP Blg. 22 cases, resort to a separate action to recover civil liability is clearly unwarranted on account of res judicata, for failure of petitioner to appeal the civil aspect of the cases. In view of this special rule governing actions for violation of BP Blg. 22, Article 31 of the Civil Code is not applicable.[19]
	GR No. 158177 2008-01-28	SPS. BENITO LO BUN TIONG and CAROLINE SIOK CHING TENG v. VICENTE BALBOA AUSTRIA-MARTINEZ, J.
In Hyatt Industrial Manufacturing Corp. v. Asia Dynamic Electrix Corp.,[12] the Court ruled that there is identity of parties and causes of action between a civil case for the recovery of sum of money as a result of the issuance of bouncing checks, and a criminal case for the prosecution of a B.P. No. 22 violation. Thus, it ordered the dismissal of the civil action so as to prevent double payment of the claim. The Court stated: x x x The prime purpose of the criminal action is to punish the offender to deter him and others from committing the same or similar offense, to isolate him from society, reform or rehabilitate him or, in general, to maintain social order. The purpose, meanwhile, of the civil action is for the restitution, reparation or indemnification of the private offended party for the damage or injury he sustained by reason of the delictual or felonious act of the accused. Hence, the relief sought in the civil aspect of I.S. No. 00-01-00304 and I.S. No. 00-01-00300 is the same as that sought in Civil Case No. MC 01-1493, that is, the recovery of the amount of the checks, which, according to petitioner, represents the amount to be paid by respondent for its purchases. x x x This was reiterated in Silangan Textile Manufacturing Corp. v. Demetria,[13] where the civil case for the recovery of the amount covered by the bouncing checks was also ordered dismissed.
	GR NO. 169647 2007-08-31	ANTONIO CHIENG v. SPS. EULOGIO AND TERESITA SANTOS CHICO-NAZARIO, J.
When petitioner filed Criminal Cases No. 612-90 to No. 615-90 for violation of Batas Pambansa Blg. 22 against respondent Eulogio, petitioner's civil action for the recovery of the amount of the dishonored checks was impliedly instituted therein pursuant to Section 1(b) of Rule 111 of the 2000 Rules on Criminal Procedure. In the case of Hyatt Industrial Manufacturing Corporation v. Asia Dynamic Electrix Corporation,[31] we elucidated thus:We agree with the ruling of the Court of Appeals that upon filing of the criminal cases for violation of B.P. 22, the civil action for the recovery of the amount of the checks was also impliedly instituted under Section 1(b) of Rule 111 of the 2000 Rules on Criminal Procedure. Under the present revised Rules, the criminal action for violation of B.P. 22 shall be deemed to include the corresponding civil action. The reservation to file a separate civil action is no longer needed. The Rules provide:
	GR NO. 166719 2007-03-12	SILANGAN TEXTILE MANUFACTURING CORPORATION v. AVELINO G. DEMETRIA CHICO-NAZARIO, J.
The case of Hyatt Industrial Manufacturing Corporation v. Asia Dynamic Electrix Corporation[16] is instructive. In that case, Hyatt Industrial Manufacturing Corporation (HIMC) instituted before the Regional Trial Court of Mandaluyong City a complaint for recovery of sum of money against respondent Asia Dynamic Electrix Corporation (ADEC). The complaint alleged that ADEC purchased from HIMC various electrical conduits and fittings amounting to P1,622,467.14. ADEC issued several checks in favor of HIMC as payment. The checks, however, were dishonored by the drawee bank on the ground of insufficient funds/account closed. Before the filing of the case for recovery of sum of money before the RTC of Mandaluyong City, HIMC had already filed separate criminal complaints for violation of Batas Pambansa Blg. 22 against the officers of ADEC, Gil Santillan and Juanito Pamatmat. They were docketed as I.S. No. 00-01-00304 and I.S. No. 01-00300, respectively, and were both pending before the Metropolitan Trial Court (MeTC) of Pasig City. These cases involved the same checks which were the subjects of Civil Case No. MC-01-1493 before the RTC of Mandaluyong City.