Case Digest (G.R. No. L-25172)
Facts:
Luis Ma. Araneta v. Antonio R. de Joya, G.R. No. L-25172, May 24, 1974, First Division, Castro, J., writing for the Court. The appeal challenges the Court of Appeals' decision (CA-G.R. 34277-R) ordering petitioner Luis Ma. Araneta to indemnify respondent Antonio R. de Joya for one-third of P5,043.20 which respondent had been adjudged to pay Ace Advertising Agency, Inc. (the plaintiff in the recovery suit); Chief Justice Makalintal, and Justices Makasiar, Esguerra and Munoz Palma concurred; Justice Teehankee took no part.In late 1952 respondent, then general manager of Ace Advertising, proposed sending employee Ricardo Taylor to the United States for television studies; the board did not act on the proposal, yet in September 1953 respondent sent Taylor abroad. Respondent told director J. Antonio Araneta that Taylor’s expenses would be borne by others and later confirmed this in a memorandum. From September 1, 1953 to March 15, 1954 Taylor continued to receive salary payments appearing in vouchers and semi-monthly payroll checks prepared upon respondent’s orders and approved by him. Petitioner, a vice-president and director, signed three of those payroll checks (November 27, December 15 and December 29, 1953); other checks were signed by respondent or by Vicente Araneta (treasurer), who also paid part of Taylor’s travel costs and gave Taylor letters for U.S. delivery. In all the corporation disbursed P5,043.20 for Taylor’s travel and studies.
On August 23, 1954 Ace Advertising sued respondent in the Court of First Instance (Manila) to recover the disbursements, alleging the trip was made without corporate knowledge, authority or ratification. Respondent denied lack of authority, claiming either board ratification or that, under the by‑laws, his discretion as general manager authorized the trip for the company’s benefit. Respondent filed a third‑party complaint against Vicente Araneta, petitioner Luis Araneta and Taylor. At trial respondent established that Vicente signed a check for part of Taylor’s transportation and that payroll checks covering Taylor’s salary were signed by Vicente and the petitioner; both Aranetas disclaimed personal liability, asserting they signed in good faith because respondent had approved the disbursements.
On April 13, 1964 the trial court ordered respondent to pay Ace Advertising P5,043.20 with legal interest from August 23, 1954, and dismissed the third‑party complaint. Respondent appealed. On August 2, 1965 the Court of Appeals affirmed the trial court’s recovery in favor of Ace Advertising but reversed the dismissal of the third‑party complaint, finding as a fact that Taylor’s trip had been neither authorized nor ratified by the company and that Vicente and Luis Araneta were privy to the unauthorized disbursements; the CA c...(Subscriber-Only)
Issues:
- Whether petitioner is liable for quasi‑delict and must indemnify respondent for one‑third of the amount respondent was ordered to pay Ace Advertising.
- Whether petitioner’s asserted good‑faith defense — that he merely signed payroll checks without personal knowledge of wrongful disbursement...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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