Case Digest (G.R. No. 233918) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Florentino v. Philippine National Bank, G.R. No. L-8782, decided April 28, 1956 under the 1935 Constitution, petitioners Marcelino B. Florentino and Lourdes T. Zandueta sought a writ of mandamus from the Court of First Instance of La Union to compel the Philippine National Bank (PNB) to accept a backpay certificate as payment for an existing loan. On January 2, 1953, the petitioners contracted a P6,800 loan from PNB, secured by a real estate mortgage and payable January 2, 1954. Marcelino held Backpay Acknowledgment No. 1721, issued October 6, 1954 pursuant to Republic Act No. 897 (approved June 20, 1953), certifying P22,896.33 due him. On December 27, 1953, petitioners offered this certificate to settle their bank indebtedness, but PNB refused on December 29, 1953. The lower court, on an agreed statement of facts, denied relief, prompting this appeal.Issues:
- Does the qualifying clause “who may be willing to accept the s
Case Digest (G.R. No. 233918) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petition and Context
- Petitioners Marcelino B. Florentino and Lourdes T. Zandueta filed a petition for mandamus in the Court of First Instance of La Union against the Philippine National Bank (PNB) to compel it to accept Florentino’s backpay certificate in payment of a P6,800 loan.
- The case was submitted on an agreed statement of facts.
- Agreed Statement of Facts
- Petitioners incurred a loan of P6,800 plus interest on January 2, 1953, due January 2, 1954, secured by a real estate mortgage.
- Marcelino B. Florentino holds Backpay Acknowledgment No. 1721 dated October 6, 1954, in the amount of P22,896.33, issued under Republic Act No. 897 (approved June 20, 1953).
- On December 27, 1953, petitioners offered to pay the loan with Florentino’s backpay certificate; on December 29, 1953, PNB refused to accept it.
- Legal Provision Involved
- Section 2, Republic Act No. 897 (amending Section 2 of RA 304) authorizes the Treasurer to acknowledge backpay rights and issue certificates redeemable by the Government within ten years without interest.
- It further provides that a certificate “shall not exceed the amount that the applicant may need for the payment of (1) obligations subsisting at the time of the approval … for which the applicant may directly be liable to the Government … or to any citizen of the Philippines, or to any association or corporation organized under the laws of the Philippines, who may be willing to accept the same for such settlement.”
Issues:
- Whether the phrase “who may be willing to accept the same for such settlement” qualifies all antecedents (Government, its branches/instrumentalities, controlled corporations, and private persons) or only the last antecedent (private persons and associations).
- Whether PNB is bound under Section 2 of RA 897 to accept Florentino’s backpay certificate in payment of his subsisting indebtedness.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)