Case Digest (G.R. No. 235771) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On June 30, 1989, International Express Travel & Tour Services, Inc. (petitioner), through its managing director, offered its services as a travel agency to the Philippine Football Federation (PFF) via its president, private respondent Henri Kahn, and the offer was accepted. Petitioner procured airline tickets for PFF athletes and officials for the Southeast Asian Games in Kuala Lumpur and other trips to the People’s Republic of China and Brisbane, amounting to ₱449,654.83. The Federation made two partial payments in September 1989 totaling ₱176,467.50. On October 4, 1989, petitioner demanded ₱265,894.33; on October 30, the Project Gintong Alay paid ₱31,603.00; and on December 27, Henri Kahn issued a personal check for ₱50,000 as partial settlement. No further payments followed. Petitioner then sued Henri Kahn in his personal capacity and as PFF president, and impleaded PFF as an alternative defendant for the outstanding balance. Kahn admitted the unpaid balance of ₱207,524.20 b Case Digest (G.R. No. 235771) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Formation of contract and services rendered
- On June 30, 1989, International Express Travel & Tour Services, Inc. (petitioner), through its Managing Director, offered travel agency services to the Philippine Football Federation (PFF) via President Henri Kahn.
- PFF accepted; petitioner procured airline tickets for the Federation’s athletes and officials to various events (SE Asian Games in Kuala Lumpur, trips to PRC and Brisbane) totaling ₱449,654.83.
- Payments and demands
- PFF made two partial payments in September 1989, totaling ₱176,467.50. On October 4, 1989, petitioner demanded the remaining ₱265,894.33.
- PFF paid ₱31,603.00 on October 30 and Henri Kahn issued a personal check for ₱50,000 on December 27, 1989. No further payments followed despite repeated demands.
- Trial court proceedings and appellate history
- Petitioner sued Henri Kahn (personally and as PFF President) and, alternatively, the PFF before the RTC of Manila for the unpaid balance (₱207,524.20). Federation was declared in default; Kahn denied personal guarantee.
- The RTC held that PFF was an unincorporated association and that Kahn was personally liable. The CA reversed, finding PFF a juridical person and dismissing the complaint against Kahn. Petitioner did not appeal dismissal of the Federation, and the CA denied the alternative prayer to hold PFF liable. Petitioner elevated the case to the Supreme Court.
Issues:
- Juridical personality of the Philippine Football Federation
- Whether PFF has valid corporate existence under law (RA 3135 and PD 604).
- Personal liability of Henri Kahn
- Whether Kahn, as PFF President, is personally liable for the unpaid airline tickets absent proof of corporate existence or a personal guarantee.
- Applicability of corporate by estoppel
- Whether petitioner is estopped from denying PFF’s corporate existence to hold Kahn personally liable.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)