Petitioners were charged of violating B.P. No. 22 by issuing worthless checks in Navotas, which were dishonored in Kalookan City.
Whether or not the place of “issue” should be the place where checks were dishonored.
NO. Under Sec. 191 of the Negotiable Instruments Law the term “issue” means the first delivery of the instrument complete in form to a person who takes it as a holder. On the other hand, the term “holder” refers to the payee or indorsee of a bill or note who is in possession of it or the bearer thereof. Here, the place of issuance is clearly Navotas.