Title
Cebu Mactan Members Center, Inc. vs. Tsukahara
Case
G.R. No. 159624
Decision Date
Jul 17, 2009
A corporation is held liable for loans secured by its President without Board approval, as the President's authority to borrow is supported by corporate by-laws.
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Case Digest (G.R. No. 159624)

Facts:

  • Cebu Mactan Members Center, Inc. (CMMCI) is the petitioner; Masahiro Tsukahara is the respondent.
  • In February 1994, CMMCI, represented by President Mitsumasa Sugimoto, secured a loan of P6,500,000 from Tsukahara.
  • CMMCI issued seven postdated checks totaling the loan amount.
  • On April 13, 1994, CMMCI obtained an additional loan of P10,000,000 from Tsukahara, with Sugimoto signing a promissory note.
  • The promissory note required payment by August 30, 1996, with an interest rate of 18% per annum.
  • The checks were dishonored upon presentation for payment.
  • Tsukahara filed a case for collection against CMMCI and Sugimoto after unsuccessful attempts to collect the total loan amount of P16,500,000.
  • CMMCI denied borrowing, claiming the loans were personal to Sugimoto and required a board resolution for corporate borrowing.
  • The Regional Trial Court ruled in favor of Tsukahara, which was affirmed by the Court of Appeals.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the petition and affirmed the Court of Appeals' decision, holding CMMCI liable for the...(Unlock)

Ratio:

  • A corporation acts through its board of directors, which has the authority to manage corporate affairs.
  • Generally, individuals, including corporate officers, cannot bind the corporation without explicit authority from the board.
  • The corporate by-laws of CMMCI granted the President the power to borrow money and execute contracts.
  • Requiring a board resolution in additi...continue reading

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