Case Digest (G.R. No. L-11977) Core Legal Reasoning Model
Facts:
In Fideliza J. Aglibot v. Ingersol L. Santia (G.R. No. 185945, December 5, 2012), private respondent Ingersol L. Santia, an engineer, extended a one-year loan of ₱2,500,000 to Pacific Lending & Capital Corporation (PLCC) through its manager, petitioner Fideliza J. Aglibot, evidenced by a promissory note dated July 1, 2003 bearing 24% annual interest. As purported security, Aglibot delivered eleven post-dated personal checks drawn on her Metrobank account. When these checks were presented for payment, they bounced due to insufficient funds or account closure. Santia filed eleven informations for violation of Batas Pambansa Blg. 22 against Aglibot in the Municipal Trial Court in Cities (MTCC), Dagupan City (Criminal Case Nos. 47664 to 47674). Aglibot admitted obtaining the loan on behalf of PLCC, contending that the checks were to be returned upon payment and denying notice of dishonor. On August 18, 2006, the MTCC acquitted her of criminal liability on reasonable doubt but o
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Case Digest (G.R. No. L-11977) Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Petitioner Fideliza J. Aglibot (Aglibot), Manager and major stockholder of Pacific Lending & Capital Corporation (PLCC).
- Private respondent Engr. Ingersol L. Santia (Santia), lender and complainant in criminal cases.
- Loan Transaction and Security
- On July 1, 2003, Santia loaned PLCC ₱2,500,000.00 evidenced by a promissory note signed by Aglibot on behalf of PLCC, payable in one year at 24% per annum.
- As security, Aglibot issued eleven post-dated personal checks drawn on her Metrobank account, purportedly as guaranty or security for PLCC’s debt.
- Dishonor and Criminal Complaints
- Upon presentment, all eleven checks were dishonored for insufficient funds or closed account.
- Santia filed eleven Informations for violation of Batas Pambansa Blg. 22 (bouncing checks) against Aglibot in MTCC Dagupan City (Criminal Case Nos. 47664–47674).
- Aglibot’s Defense
- Admitted the loan on behalf of PLCC and claimed Santia agreed not to deposit checks but to return them upon payment; denied receiving notice of dishonor.
- Asserted she was a mere guarantor and Santia failed to exhaust remedies against PLCC.
- Lower Court Decisions
- MTCC Joint Decision (Aug. 18, 2006): Acquitted Aglibot for lack of notice; ordered her to pay Santia ₱3,000,000.00 (face value plus 12% p.a. interest from filing, attorney’s fees, costs).
- RTC Decision (Apr. 3, 2007): Reversed MTCC civil liability; dismissed civil aspect for failure to exhaust remedies against PLCC as principal debtor. Motion for reconsideration denied (June 12, 2007).
- CA Decision (Mar. 18, 2008): Reversed RTC; held Aglibot personally liable as an accommodation party, ordered payment of ₱3,000,000.00 with 12% p.a. interest from filing until finality, then compounded at 12% p.a. Motion for reconsideration denied (Dec. 23, 2008).
- Petition for Review
- Aglibot filed a Rule 45 petition before the Supreme Court seeking to annul the CA Decision.
Issues:
- Whether petitioner Aglibot, having issued her personal checks on behalf of PLCC, may invoke the benefit of excussion as a guarantor and avoid personal liability.
- Whether the absence of a written guaranty agreement under the Statute of Frauds precludes treating Aglibot as a guarantor.
- Whether, under the Negotiable Instruments Law, Aglibot is instead an accommodation party with immediate and unconditional liability.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)