Case Digest (G.R. No. 24224)
Facts:
- The case involves the Philippine National Bank (PNB) as the plaintiff and Ramon Maza and Francisco Mecenas as the defendants.
- The dispute centers on five promissory notes, each worth ten thousand pesos (P10,000), signed by Maza and Mecenas.
- The first two notes were signed on January 20, 1921, with a maturity of three months, while the remaining three were executed on January 21, 1921, maturing four months later.
- The notes were payable to the order of the Philippine National Bank in Iloilo.
- By September 22, 1924, the total amount due, including interest, was P65,207.73.
- PNB filed a lawsuit in the Court of First Instance of Iloilo to recover the owed amounts.
- Maza and Mecenas claimed the notes were sent to them blank by Enrique Echaus, who requested their signatures for potential negotiation.
- They argued they had not negotiated the notes or received value, asserting Echaus was the real party in interest.
- The trial court denied their motion to add Echaus as a defendant and ruled in favor of PNB, ordering Maza and Mecenas to pay the total amount due, interest, and costs.
- The defendants appealed, citing four errors, including the refusal to compel Echaus to join the case.
Issue:
- (Unlock)
Ruling:
- The court ruled that the trial court did not err in refusing to require Enrique Echaus to become a party to the action, as the defendants failed to properly except to the order and Echaus was not an indispensable party.
- Maza and Mecenas were found liable for the amounts stated in the promissory notes, as they admitted the genuineness and due execution of the instruments.
- The court held that the defense of...(Unlock)
Ratio:
- The court's decision was based on principles of agency and the nature of negotiable instruments.
- Maza and Mecenas, as signatories of the promissory notes, had a primary and unconditional obligation to fulfill their commitments, regardless of their claims regardi...continue reading
Case Digest (G.R. No. 24224)
Facts:
The case involves the Philippine National Bank (PNB) as the plaintiff and Ramon Maza and Francisco Mecenas as the defendants. The dispute arose from five promissory notes, each amounting to ten thousand pesos (P10,000), executed by Maza and Mecenas. The first two notes were signed on January 20, 1921, and were due three months later, while the remaining three notes were executed on January 21, 1921, with a maturity of four months after their date. The notes were structured to be paid to the order of the Philippine National Bank in Iloilo. By September 22, 1924, the total amount due, including accumulated interest, reached P65,207.73. The PNB initiated legal action in the Court of First Instance of Iloilo to recover the amounts owed.
In their defense, Maza and Mecenas claimed that the promissory notes were sent to them in blank by Enrique Echaus, who requested their signatures for potential negotiation with the bank. They argued that they had neither negotiated the notes nor received any value from them, asserting that Echaus was the real party in interest and should be included as a defendant. The trial court denied their motion to add Echaus as a party and ultimately ruled in favor of the PNB, ordering Maza and Mecenas to pay the total amount due, along with interest and costs. The defendants appealed, raising four errors, including the refusal to compel Echaus to join ...