Case Digest (G.R. No. 94713)
Facts:
Mansion Biscuit Corporation v. Court of Appeals, G.R. No. 94713, November 23, 1995, First Division, Kapunan, J., writing for the Court. Petitioner is Mansion Biscuit Corporation (represented by its president Ang Cho Hong); respondents are the heirs-substitutes of Ty Teck Suan and co-accused Siy Gui, and the Court of Appeals as the respondent tribunal in the petition for review.
Sometime in 1981 Ty Teck Suan, as president of Edward Ty Brothers Corporation, ordered numerous cartons of nutri-wafer biscuits from Mansion Biscuit Corporation. Before delivery, Ty issued four postdated checks (totaling P404,980) and later four additional postdated checks (P100,000 each), some co-signed by Siy Gui. Mansion delivered the goods between November 12, 1981 and January 7, 1982. The first batch of checks presented in December 1981–January 1982 were dishonored for insufficiency of funds; complainant demanded payment and later received deliveries of flour and some cash from Ty which were applied to one of the earlier checks.
After formal demand letters and continued dishonors of the second batch of checks (dated March–May 1982), Mansion filed criminal informations for violation of Batas Pambansa Blg. 22 (the Bouncing Checks Law) against Ty (Criminal Case No. 5598‑V‑83) and against Ty and Siy Gui (Criminal Case No. 5599‑V‑83). The informations alleged that the checks were issued in payment for the biscuits delivered by Mansion to Edward Ty Brothers Corporation through Ty.
At trial the prosecution rested and the accused moved for dismissal by demurrer to evidence. On October 12, 1987, the Regional Trial Court (Judge Teresita Dizon‑Capulong) granted the demurrer, ruling that the checks had been issued as guarantees of payment and therefore did not constitute a violation of B.P. Blg. 22; the trial court acquitted both accused and set aside a previously issued order of attachment. The court also held that no civil liability could be adjudicated in the criminal cases in view of the acquittal.
Petitioner sought reconsideration as to the civil aspect and separately filed a special civil action (CA‑G.R. SP No. 13264) with the Court of Appeals challenging only the setting aside of the attachment; the Court of Appeals on February 22, 1988 annulled that portion of the trial court order and reinstated the attachment. Meanwhile, petitioner appealed the trial court's dismissal of civil liability in CA‑G.R. CV No. 16580. Ty died on January 10, 1989 and his heirs were substituted; the Court of Appeals denied dismissal and allowed substitution.
On May 8, 1990, the Court of Appeals in CA‑G.R. CV No. 16580 dismissed petitioner's appeal on the merits, holding that the unpaid value of the biscuits was a contractual obligation of Edward Ty Brothers Corporation, not the personal liability of Ty; because the corporation was not a party to the criminal cases, its liability could not be litigated therein and petitioner must file a separate civil action against the corporation. The Court of Appeals also held that any tort/quasi‑delict claim would likewise be directed against the corporation since the alleged wrongful acts were incidental to the contractual relationship.
Petitioner then brought the present petition for review to the Supreme Court seeking reversal of the Cour...(Pro-only)
Issues:
- May Mansion Biscuit Corporation enforce the civil liability for non‑payment of the delivered nutri‑wafer biscuits against Ty Teck Suan (and his heirs) and Siy Gui personally, when the purchases were made by Edward Ty Brothers Corporation through Ty as its president?
- Did the acquittal of Ty Teck Suan and Siy Gui in the criminal cases extinguish any civil liability other than that arising solely from the crime, i.e., does a civil action based on quasi‑delict survive ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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