THERESA MACALALAG, petitioner, vs. PEOPLE O THE PH!L!PP!NES, respondent. Facts: Petitioner Theresa Macalalag obtained loans from Grace Estrella, each in the amount of P100,000.00. s securit! for the pa!ment of the aforesaid loans, petitioner Macalalag issued t"o Philippine #ational $an% &P#$' chec%s. (o"ever, "hen Estrella presented said chec%s for pa!ment "ith the dra"ee ban%, the same "ere dishonored for the reason that the account against "hich the same "as dra"n "as alread! closed. Estrella sent a notice of dishonor and demand to ma%e good the said chec%s to Macalalag, but the latter failed to do so. (ence, Estrella filed t"o criminal complaints for )iolation of $atas Pambansa $lg. **. Petitioner Macalalag claims that, considering that she had alread! paid P1+,,000.00 at the time the sub-ect chec%s "ere presented for pa!ment, the amount of P100,000.00 should be applied for redemption of the first chec% and the remaining amount of P+,,000.00 should be treated as partial redemption of the second chec%. Petitioner Macalalag posits that said partial redemption e.empts her from criminal liabilit! because it "as made before the chec% "as presented for pa!ment. /ssue: 0hether or not petitioner Macalalag is e.empted from criminal liabilit! based on the partial redemption of the second chec%. (eld: #o. /t is "ell to note that the gravamen of $atas Pambansa $lg. ** is the issuance of a chec%, not the nonpa!ment of an obligation. 11 The la" has made the act of issuing a bum chec% a malum prohibitum. 12 3onse4uentl!, the lac% of criminal intent on the part of the accused is irrelevant. /n the case at bar, onl! a full pa!ment of the face value of the second chec% at the time of its presentment or during the five5da! grace period 1+ could have e.onerated her from criminal liabilit!. contrar! interpretation "ould defeat the purpose of $atas Pambansa $lg. **, that of safeguarding the interest of the ban%ing s!stem and the legitimate public chec%ing account user, 1, as the dra"er could ver! "ell have himself e.onerated b! the mere e.pedienc! of pa!ing a minimal fraction of the face value of the chec%. #either could petitioner Macalalag6s subse4uent pa!ment of P122,178.21 during the pendenc! of the cases against her before the MT33 result in freeing her from criminal liabilit! because the same had alread! attached after the chec% "as dishonored. 9aid subse4uent pa!ments can onl! affect her civil, not criminal, liabilit!. subse4uent pa!ment b! the accused "ould not obliterate the criminal liabilit! theretofore alread! incurred. 18