Facts:

• Mansion Biscuit Corporation, led by president Ang Cho Hong, filed a petition for review against the Court of Appeals and private respondents Ty Teck Suan, Siy Gui, and the heirs of Ty Teck Suan.
• The case began in 1981 when Ty Teck Suan, as president of Edward Ty Brothers Corporation, ordered nutri-wafer biscuits from Mansion Biscuit Corporation.
• Ty issued four postdated checks totaling P404,980.00, with additional checks later signed by Siy Gui.
• The checks were dishonored due to insufficient funds, leading Mansion Biscuit Corporation to demand payment, which Ty Teck Suan failed to provide.
• Criminal charges were filed against Ty Teck Suan and Siy Gui under Batas Pambansa Bilang 22 (Bouncing Checks Law).
• The trial court acquitted both defendants, stating the checks were guarantees for contract fulfillment rather than payments for a debt.
• Mansion Biscuit Corporation sought to enforce civil liability against the respondents, arguing that the acquittal did not extinguish their civil liabilities.
• The Court of Appeals dismissed the appeal, ruling that the civil liability was a contractual obligation of Edward Ty Brothers Corporation, not a personal obligation of Ty Teck Suan.

Issue:

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Ruling:

• The Supreme Court affirmed the Court of Appeals' decision, ruling that the civil liability for the non-payment of the nutri-wafer biscuits was not Ty Teck Suan's personal liability but a contractual obligation of Edward Ty Brothers Corporation.
• The acquittal of Ty Teck S...(Unlock)

Ratio:

• The Court distinguished between personal and corporate liability, emphasizing that the checks were issued in a corporate context, with Ty Teck Suan acting as president of Edward Ty Brothers Corporation.
• The checks were not personal guarantees but part of the c...continue reading