Case Digest (G.R. No. 175587) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Philippine Commercial International Bank v. Joseph Anthony M. Alejandro, PCIB filed on October 23, 1997 in the Regional Trial Court of Makati a complaint for sum of money against respondent Alejandro, alleging that he executed on September 10, 1997 a promissory note for ₱249,828,588.90 plus interest and assigned peso deposits as security. Due to foreign‐exchange fluctuations that depleted the initial security, PCIB demanded additional collateral; Alejandro complained of mishandling when his instruction to close his account in April 1997 went unheeded. PCIB then secured an ex parte writ of preliminary attachment under Rule 57, Sections 1(e) and (f), on the grounds that Alejandro fraudulently withdrew unassigned deposits and was a non‐resident, posting an ₱18,798,734.69 bond with Prudential Guarantee & Assurance, Inc. and garnishing his RCBC deposits. Alejandro voluntarily submitted to jurisdiction, but on December 24, 1997 moved to quash the writ, contending the withdrawals we Case Digest (G.R. No. 175587) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Complaint for money and issuance of writ of preliminary attachment
- On October 23, 1997, Philippine Commercial International Bank (PCIB) sued Joseph Anthony M. Alejandro for ₱249,828,588.90 under a promissory note and prayed for ex parte preliminary attachment under Rule 57, Sections 1(e) and (f), alleging (a) fraudulent withdrawal of unassigned deposits and (b) respondent’s non-residence in the Philippines.
- On October 24, 1997, the Regional Trial Court of Makati granted the writ after PCIB posted a bond of ₱18,798,734.69, and garnished respondent’s deposits with RCBC.
- Quashal of the writ and finality of findings
- On October 27, 1997, respondent voluntarily submitted to the court’s jurisdiction and filed a motion to quash the writ, contending (a) no intent to defraud since withdrawals were approved by PCIB, and (b) he maintained residence and office addresses in Quezon City and Makati.
- On December 24, 1997, the trial court granted the motion, finding no fraudulent intent and misrepresentation by PCIB regarding respondent’s residence; its order was affirmed on PCIB’s certiorari petitions before the Court of Appeals and this Court, becoming final.
- Proceedings on damages
- On May 20, 1998, respondent filed a claim for ₱25 million damages against the attachment bond for wrongful garnishment; evidence showed dishonored checks and proof of professional standing.
- On August 30, 2000, the trial court awarded ₱25 million (₱18.8 million bond + ₱6.2 million from PCIB). The Court of Appeals (May 31, 2006) deleted the ₱25 million, awarding instead ₱2 million nominal, ₱5 million moral, and ₱1 million attorney’s fees; on reconsideration it added ₱5 million exemplary damages.
- PCIB filed a petition for review before this Court.
Issues:
- Is PCIB liable for damages for the wrongful issuance of the writ of attachment?
- Can PCIB invoke good faith or alternative grounds under Rule 57(f) (residence out of the Philippines)?
- What are the proper quantum and classification of damages?
- Does the claim for damages survive the dismissal of the main money claim?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)