Case Digest (G.R. No. L-27155) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Philippine National Bank v. Court of Appeals, petitioner Philippine National Bank (PNB) was impleaded as third-party defendant in a suit brought by Philippine American General Insurance Company, Inc. (Philamgen) against Rita Gueco Tapnio and Cecilio Gueco. Philamgen, as surety, had paid P2,379.71 plus interest to PNB on September 18, 1957 to cover Tapnio’s unpaid bank obligations under an indemnity agreement. Tapnio then filed a third-party complaint against PNB, alleging that her failure to pay the loan was due to PNB’s unreasonable refusal to approve her lease of an excess sugar quota. Tapnio had contracted to lease 1,000 piculs of her 1956–1957 export sugar quota to Jacobo Tuazon at P2.80 per picul, an amount Tuazon was ready to pay from an approved PNB loan. Although the PNB branch manager and vice‐president recommended approval, the PNB Board of Directors insisted on P3.00 per picul. Tuazon rescinded, causing Tapnio a P2,800.00 loss. The Court of First Instance of Manila Case Digest (G.R. No. L-27155) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Bond and Indemnity Agreement
- Philippine American General Insurance Co., Inc. (Philamgen) executed a surety bond (Exh. A) with Rita Gueco Tapnio as principal in favor of Philippine National Bank (PNB), San Fernando, Pampanga, to guarantee Tapnio’s bank obligations.
- Tapnio and her husband Cecilio Gueco signed an indemnity agreement (Exh. B) promising to reimburse Philamgen for any amount paid, plus 12% annual interest and 15% attorney’s fees if litigation ensued.
- Default, Payment and Main Action
- Tapnio’s bonded indebtedness amounted to P2,000 plus accrued interest; she defaulted despite the bank’s demand (Exh. C).
- Philamgen paid P2,379.71 on September 18, 1957 (Exhs. D, D-1) to PNB and thereafter sued Tapnio and Gueco for reimbursement; Tapnio and Gueco impleaded PNB as third-party defendant, alleging its negligence caused their failure to pay.
- Sugar Quota Lease Negotiation
- Tapnio owned an unused export sugar quota of 1,000 piculs for crop year 1956-1957. She contracted to lease it to Jacobo Tuazon at P2.50 per picul (Exh. 4), subject to PNB approval because the quota was mortgaged to PNB.
- The PNB branch manager required raising the rental to P2.80 per picul; Tuazon agreed (letter dated August 10, 1956). The Vice-President concurred, but PNB’s Board of Directors demanded P3.00 per picul. Unable to meet this demand, Tuazon rescinded the lease on February 22, 1957, causing Tapnio to lose P2,800.
- Procedural History
- The Court of First Instance of Manila ordered PNB to pay Tapnio P2,379.71 plus 12% interest from September 19, 1957, P200 attorney’s fees to Philamgen, and P500 attorney’s fees to Tapnio.
- The Court of Appeals affirmed. PNB’s motion for reconsideration was denied. PNB then filed this certiorari petition before the Supreme Court.
Issues:
- Unjustified Lease Disapproval
- Did the Court of Appeals err in finding that PNB’s refusal to approve the lease at P2.80 per picul and insistence on P3.00 per picul unjustifiably caused the contract rescission and Tapnio’s loss?
- Board’s Authority to Fix Rental
- Did the Court of Appeals err in not holding that PNB’s Board validly exercised its charter and corporate power to fix the rental at P3.00 per picul based on prevailing sugar-price statistics?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)