Title
Batchelder vs. Central Bank of the Philippines
Case
G.R. No. L-25071
Decision Date
Jul 29, 1972
Plaintiff alleged Central Bank's obligation to resell dollars at a specific rate; court ruled no contractual or legal duty existed.
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Case Digest (G.R. No. L-25071)

Facts:

  1. Parties Involved:

    • Plaintiff-Appellant: George W. Batchelder, doing business under the name and style of Batchelder Equipment.
    • Defendant-Appellant: The Central Bank of the Philippines.
  2. Nature of the Case:

    • The plaintiff-appellant filed a case against the Central Bank of the Philippines, alleging that the Central Bank was obligated to resell US$154,094.56 to him at an exchange rate of P2.00375 to US$1.00.
  3. Initial Claim:

    • The plaintiff initially argued that there was a contract between him and the Central Bank that obligated the latter to resell the dollars at the specified exchange rate.
  4. Shift in Argument:

    • In the motion for reconsideration, the plaintiff abandoned the contract argument and instead claimed that the obligation arose from law, specifically from the Central Bank's circulars and regulations, which he argued had the force and effect of law.
  5. Central Bank's Role:

    • The Central Bank acted as a regulatory agency managing the currency and issued circulars to implement its statutory objectives, such as maintaining monetary stability and preserving the international value of the peso.
  6. Lower Court Decision:

    • The lower court ruled in favor of the plaintiff, but the Supreme Court reversed this decision, holding that the Central Bank did not assume any contractual obligation to the plaintiff.

Issue:

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Ruling:

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Ratio:

  1. Obligations Arising from Law:

    • Obligations arising from law are not presumed and must be clearly demonstrated. The plaintiff failed to show that any legal provision or administrative regulation imposed such an obligation on the Central Bank.
  2. Central Bank's Role as a Regulatory Agency:

    • The Central Bank acted in its capacity as a regulatory body tasked with managing the currency and maintaining monetary stability. Its issuance of circulars and regulations was an exercise of its quasi-legislative powers, not an assumption of contractual obligations.
  3. Force and Effect of Administrative Regulations:

    • While administrative regulations, such as Central Bank circulars, may have the force and effect of law, they do not automatically create obligations unless explicitly stated. The plaintiff failed to prove that the Central Bank intended to impose such an obligation on itself.
  4. No Vested Right Acquired:

    • The plaintiff did not comply with the rules and regulations of the Central Bank, and therefore, no vested right to the exchange rate of P2.00375 to US$1.00 was acquired.
  5. Judicial Oversight of Administrative Agencies:

    • The Court emphasized the importance of judicial deference to the expertise of administrative agencies in fulfilling their statutory objectives. Substituting judicial discretion for administrative expertise could frustrate the objectives of the law.


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