Case Digest (G.R. No. 150175) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Alvin Patrimonio v. Napoleon Gutierrez and Octavio Marasigan III (G.R. No. 187769, June 4, 2014), petitioner Alvin Patrimonio, a professional basketball player, and respondent Napoleon Gutierrez, a sports columnist, formed Slam Dunk Corporation in Quezon City to produce basketball‐related shows. To cover corporate expenses, Patrimonio pre-signed blank checks and entrusted them to Gutierrez with the express instruction that no blanks be filled or checks negotiated without his prior approval. In early 1994, Gutierrez secretly obtained a loan of ₱200,000 from Octavio Marasigan III, a former teammate of Patrimonio, claiming the money was needed for Patrimonio’s house. He delivered one of the blank pre-signed checks (Pilipinas Bank Check No. 21001764) to Marasigan, filling the date as May 23, 1994 and the amount as “Two Hundred Thousand Pesos Only.” When Marasigan deposited the check on May 24, 1994, the bank dishonored it with the remark “ACCOUNT CLOSED,” as Patrimonio’s account Case Digest (G.R. No. 150175) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Formation and operations of Slam Dunk Corporation
- Petitioner Alvin Patrimonio, a professional basketball player, and respondent Napoleon Gutierrez, a sports columnist, formed Slam Dunk Corporation to produce mini-concerts and basketball shows.
- Patrimonio pre-signed several blank checks (no payee, date, or amount) and entrusted them to Gutierrez, expressly instructing that they be filled out and used only with his prior knowledge and approval, to cover business expenses.
- Unauthorized loan transaction
- In mid-1993, without Patrimonio’s consent, Gutierrez requested a P200,000 loan from respondent Octavio Marasigan III, allegedly for Patrimonio’s house construction, promising 5% monthly interest.
- Gutierrez delivered one pre-signed blank check (Pilipinas Bank Check No. 21001764), filled in as “Cash – Two Hundred Thousand Pesos Only,” dated May 23, 1994. The check bounced for “Account Closed” (account closed since May 28, 1993).
- Judicial proceedings
- Criminal case: Marasigan filed a B.P. 22 case (No. 42816) against Patrimonio; civil case: Patrimonio filed for nullity of loan and damages against Gutierrez and Marasigan in RTC Branch 77, Quezon City.
- RTC Decision (Feb. 3, 2003): Gutierrez in default; held Marasigan a holder in due course; dismissed nullity complaint; ordered Patrimonio to pay P200,000, with right to reimbursement from Gutierrez.
- CA Decision (Sept. 24, 2008): Agreed Patrimonio never authorized loan; held Marasigan not a holder in due course; nonetheless ruled loan not void (grounded in law); affirmed Patrimonio’s liability to pay P200,000. Motion for reconsideration denied (Apr. 30, 2009).
- Petition: Patrimonio sought SC review under Rule 45, arguing absence of authorization, necessity of written SPA (Art. 1878, Civil Code), no holder in due course status for Marasigan, and entitlement to damages.
Issues:
- Can the P200,000 loan contract be nullified as void for lack of authorization by Patrimonio?
- Is Patrimonio liable to pay the P200,000 loan to Marasigan?
- Did Gutierrez strictly fill out the pre-signed check within the authority granted by Patrimonio?
- Is Marasigan a holder in due course of the check?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)