Title
Florentino vs. Philippine National Bank
Case
G.R. No. L-8782
Decision Date
Apr 28, 1956
Petitioners offered a backpay certificate to settle a PNB loan; PNB refused. SC ruled the certificate must be accepted, reversing the lower court, as the law mandates government entities to honor such payments.

Case Digest (G.R. No. 233918)
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)

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