Case Digest (G.R. No. 234329) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Benjamin T. De Leon, Jr. vs. Roqson Industrial Sales, Inc. (G.R. No. 234329, November 23, 2021), petitioner Benjamin T. De Leon, Jr., managing director of RB Freight International, Inc., issued RCBC Check No. 0201234 dated August 25, 2006 for ₱436,800.00 in payment for 12,000 liters of diesel delivered by respondent Roqson Industrial Sales, Inc. Upon presentment, the check was dishonored for insufficient funds in a closed account. Respondent sent its first demand letter on September 15, 2006 to RB Freight and petitioner; RB Freight’s administrative manager, Mean Ramos, replied on September 18 proposing a settlement, which respondent tentatively accepted. On October 14, 2006, RB Freight’s Board rejected the proposal and sought a debt moratorium. With no agreement reached, respondent sent a final demand via registered mail on November 3, 2006. When payment was not made, a criminal complaint for violation of Batas Pambansa Blg. 22 (B.P. 22) was filed against petitioner before th...
Case Digest (G.R. No. 234329) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Underlying Transaction and Dishonor
- Benjamin T. De Leon, Jr., as managing director of RB Freight International, Inc., issued RCBC Check No. 0201234 dated August 25, 2006 for ₱436,800.00 to Roqson Industrial Sales, Inc. in payment for 12,000 liters of diesel.
- Upon presentment, the check was dishonored due to a “closed account.”
- Demand Correspondence and Criminal Complaint
- Roqson sent demand letters:
- September 15, 2006 to RB Freight and petitioner; reply by RB Freight’s administrative manager on September 18 proposing a settlement.
- October 14, 2006 rejection by RB Freight’s Board and request for moratorium.
- Final demand via registered mail (registry receipt and return card) left unheeded.
- Roqson filed a criminal complaint under B.P. 22. The City Prosecutor found probable cause; trial ensued before the Metropolitan Trial Court of Quezon City (METC).
- Lower Court Decisions
- METC (May 28, 2013): acquitted petitioner of B.P. 22 for failure to prove knowledge of insufficiency of funds; imposed civil liability for:
- ₱436,800.00 plus 6% legal interest per annum from last demand (November 3, 2006) until full payment;
- ₱30,000.00 attorney’s fees plus ₱2,000.00 per appearance;
- Costs of suit.
- RTC (February 23, 2015): affirmed METC’s acquittal; modified interest to 12% per annum from judicial demand (October 3, 2007); retained attorney’s fees and costs.
- CA (April 20, 2017): denied petitioner’s appeal; modified interest to 12% per annum from October 3, 2007 to June 30, 2013, then 6% per annum from July 1, 2013 until full payment; affirmed civil liability for face value.
- Supreme Court Petition and Contentions
- Petitioner’s Arguments:
- Underlying debt was corporate (RB Freight’s) – he cannot be personally liable.
- No finding of fraud or bad faith against him.
- Acquittal on B.P. 22 precludes civil liability.
- Respondent’s Arguments:
- By issuing his personal check, petitioner assumed personal liability as accommodation party.
- Civil liability for the check is distinct from the corporate purchase obligation.
- Cite Aglibot v. Santia: accommodation parties liable despite no value received.
Issues:
- Whether the Court of Appeals erred in affirming petitioner’s civil liability for the face value of the dishonored check (₱436,800.00).
- Whether petitioner’s acquittal on B.P. 22 precludes any civil liability (“ex delicto”) for the bounced check.
- Whether petitioner is personally liable as an accommodation party under Section 29 of the Negotiable Instruments Law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)