Case Digest (G.R. No. 136729) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Astro Electronics Corp. and Peter Roxas v. Philippine Export and Foreign Loan Guarantee Corporation, decided on September 23, 2003, Astro Electronics Corp. (“Astro”) obtained several loans from Philippine Trust Company totaling ₱3,000,000, evidenced by three promissory notes: PN No. PFX-254 (₱600,000, dated December 14, 1981), PN No. PFX-258 (₱400,000, December 14, 1981) and PN No. 15477 (₱2,000,000, August 27, 1981). In each instrument, Peter T. Roxas signed twice—once as President of Astro and again purportedly in his personal capacity—and also executed a Continuing Suretyship Agreement in both capacities. Subsequently, Philguarantee agreed to guarantee 70% of Astro’s indebtedness to Philtrust, with subrogation rights upon payment. When Astro defaulted, Philguarantee paid the guaranteed portion and filed a complaint for sum of money with the Regional Trial Court (RTC) of Makati against Astro and Roxas for ₱3,621,187.52 plus interest and costs. Roxas denied personal liabilit Case Digest (G.R. No. 136729) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Loan Transactions and Security
- Astro Electronics Corp. (Astro) obtained several loans from Philippine Trust Company (Philtrust) totaling ₱3,000,000.00.
- Loans were evidenced by three promissory notes:
- PN No. PFX-254 (Dec. 14, 1981) for ₱600,000.00.
- PN No. PFX-258 (Dec. 14, 1981) for ₱400,000.00.
- PN No. 15477 (Aug. 27, 1981) for ₱2,000,000.00.
- Peter Roxas signed each note twice: once as Astro’s President and once in his personal capacity.
- Roxas also executed a Continuing Suretyship Agreement, binding himself as surety for Astro’s indebtedness to Philtrust.
- Guarantee and Default
- Philguarantee, with Astro’s consent, guaranteed 70% of Astro’s loan obligations to Philtrust, agreeing to subrogation upon payment.
- Astro defaulted on its loan obligations; Philguarantee paid Philtrust 70% of the guaranteed amount.
- Philguarantee filed suit in the RTC of Makati against Astro and Roxas for sums paid.
- Trial Court Proceedings
- Roxas denied personal liability, claiming the “personal capacity” notation was fraudulently inserted post-signature.
- RTC found Roxas’s dual signature conclusive of his intent to bind himself personally and officially.
- RTC rendered judgment ordering Astro and Roxas, jointly and severally, to pay ₱3,621,187.52 plus 16% interest and costs.
- Appellate Proceedings
- Court of Appeals affirmed the RTC, upholding the presumption of fairness in private transactions and Roxas’s unexplained dual signature.
- Petition for review under Rule 45 was filed by Astro and Roxas before the Supreme Court.
Issues:
- Joint and Several Liability
- Whether Peter Roxas, by signing the promissory notes twice, is solidarily liable with Astro for the indebtedness.
- Whether his personal signature obligates him as a co-maker irrespective of the “personal capacity” notation.
- Subrogation Rights of Philguarantee
- Whether Philguarantee, having paid 70% of the loan, was validly subrogated to Philtrust’s rights against Astro and Roxas.
- Whether subrogation occurred legally, without Roxas’s consent.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)