G.R. No. 167552 - Eurotech Industrial Technologies, Inc. vs. Cuizon

Petitioner Eurotech Industrial Technologies, Inc. is engaged in importing and distributing European industrial equipment in the Philippines.
Respondent Erwin Cuizon is the sole proprietor of Impact Systems Sales; respondent Edwin Cuizon is its sales manager, sued in that capacity.

From January to April 1995, petitioner sold Impact Systems goods valued at ₱91,338.00 on credit.
Respondents later ordered one Selwood Spate 100D sludge pump valued at ₱250,000.00, making a ₱50,000.00 down payment.
Petitioner withheld delivery pending full settlement; on June 28, 1995, Edwin (as agent) and petitioner’s general manager executed a Deed of Assignment assigning Impact Systems’ receivables of ₱365,000.00 from Toledo Power Corporation to petitioner.
Petitioner delivered the pump on June 30, 1995; respondents then collected the assigned receivables (₱365,135.29) from Toledo Power without notifying petitioner.

Petitioner’s demands prompted partial payments; final demand letter dated October 7, 1996 placed outstanding debt at ₱295,000.00 (excluding interests and fees).
On January 8, 1997, RTC Cebu City Branch 8 issued a writ of preliminary attachment.
Edwin admitted the sale transactions in his January 1997 Answer but claimed he acted only as agent and disputed the amount owing.
On June 26, 1998, petitioner moved to declare Erwin in default and for summary judgment; default against Erwin was entered, but summary judgment was denied on August 31, 2001.
Pre‐trial was deferred pending resolution of Edwin’s special and affirmative defenses; on January 29, 2002, the trial court dropped Edwin as party defendant.
On August 10, 2004, the Court of Appeals affirmed the RTC’s order; its March 17, 2005 resolution denied reconsideration.
Petitioner then filed a petition for certiorari before the Supreme Court.

Whether Edwin Cuizon, acting as agent, is personally liable for the obligations arising from the Deed of Assignment under Article 1897 of the New Civil Code.
Whether Edwin exceeded the scope of his authority or expressly bound himself, thereby incurring personal liability.
Whether the respondents engaged in a fraudulent conspiracy that would render Edwin personally liable despite his agency status.