Ladonga v. People, G.R. No.

141066,

17 February 2005

FACTS:

Accused was charged with her husband violation of BP 22 for issuing checks on closed account.

RTC found her husband guilty and the accused as co-conspirator of the said crime.

Conspiracy to commit violation of BP 22 is valid. Hence this case

Issue:

Whether the RPC is suppletory to BP 22

HELD:

Yes, B.P. Blg. 22 does not expressly proscribe the suppletory application of the provisions of the
RPC. Thus, in the absence of contrary provision in B.P. Blg. 22, the general provisions of the
RPC which, by their nature, are necessarily applicable, may be applied suppletorily.