Case Digest (G.R. No. 120639) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In BPI Express Card Corporation vs. Court of Appeals and Ricardo J. Marasigan, G.R. No. 120639, decided on September 25, 1998, private respondent Atty. Ricardo J. Marasigan was a complimentary member of petitioner BPI Express Card Corporation (BECC) from February 1988 to February 1990. He was issued Credit Card No. 100-012-5534 with an initial credit limit of ₱3,000, later raised to ₱5,000. Despite occasional excesses and late payments, BECC tolerated his mode of settlement by check. Marasigan’s October 1989 statement of account totaling ₱8,987.84 went unpaid because he was attending to matters in Quezon Province. BECC demanded immediate payment and required a ₱15,000 postdated check to cover both past and future bills, threatening suspension if not complied with. Marasigan issued Far East Bank Check No. 494675 postdated December 15, 1989, which BECC received on November 23, 1989. On November 28, 1989, BECC sent Marasigan a letter by ordinary mail warning of temporary suspension Case Digest (G.R. No. 120639) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Issuance and renewal of credit card
- Private respondent Ricardo J. Marasigan, a lawyer, became a complimentary member of BPI Express Card Corporation (BECC) in February 1988 and was issued Card No. 100-012-5534 with a ₱3,000 credit limit and monthly billing.
- Membership and credit limit were renewed in February 1989, increasing the limit to ₱5,000.
- Defaults and postdated check arrangement
- Marasigan frequently exceeded his credit limit but payments were tolerated until his October 1989 statement (₱8,987.84) remained unpaid. He was out of town and inadvertently failed to pay on time.
- BECC demanded immediate payment of outstanding and future bills totaling ₱15,000. On November 23, 1989, Marasigan issued a postdated check (Far East Bank No. 494675) for ₱15,000, delivered to BECC staff Tess Lorenzo and held by collections head Roberto Maniquiz.
- Suspension notice and dishonor at Café Adriatico
- On November 28, 1989, BECC mailed Marasigan a letter informing him of temporary suspension of his card and inclusion in its caution list unless he paid within five days; there was no proof he received this before December 8.
- On December 8, 1989, Marasigan’s card was dishonored at Café Adriatico (₱735.32). A guest paid with her own card.
- Subsequent correspondence and legal proceedings
- Marasigan wrote letters (December 12, 1989; December 16, 1989; March 12, 1990) rescinding the postdated check, demanding billing details, and threatening court action for humiliation.
- BECC sent a final demand (March 21, 1990) for full payment and cash replacement of check; Marasigan replied on April 5, 1990. He then filed a complaint (May 7, 1990) for moral, exemplary damages, and attorney’s fees before the Makati RTC.
- Trial court and Court of Appeals decisions
- RTC ruled Marasigan’s card suspension was abusive under Civil Code Art. 19, awarding ₱100,000 moral damages, ₱50,000 exemplary damages, and ₱20,000 attorney’s fees, less his unpaid ₱14,439.41.
- On appeal, the Court of Appeals affirmed with modification: ₱50,000 moral damages, ₱25,000 exemplary damages, and ₱10,000 attorney’s fees.
Issues:
- Whether BECC and Marasigan entered into an agreement conditioning continued card honor on issuance of a ₱15,000 postdated check.
- Whether BECC is liable for moral damages, exemplary damages, and attorney’s fees due to the card’s dishonor.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)