Case Digest (G.R. No. 24224)
Facts:
The case involves the Philippine National Bank as the plaintiff-appellee and Ramon Maza and Francisco Mecenas as the defendants-appellants. On January 20 and 21, 1921, Maza and Mecenas executed five promissory notes payable to the Philippine National Bank, each amounting to ten thousand pesos (P10,000), with maturities three and four months after their respective dates of execution. These promissory notes were due but were not paid by Maza and Mecenas at maturity. The bank sought to recover the unpaid principal plus accumulated interest amounting to P65,207.73 as of September 22, 1924. The defendants’ special defense was that the notes were sent to them unsigned but in blank by Enrique Echaus, who requested their signatures so that he could negotiate them with the bank if necessary. The defendants claimed they never negotiated or received value for the notes, asserting that Echaus was the real party liable. They moved for Echaus to be included as a defendant, which the trial co
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Case Digest (G.R. No. 24224)
Facts:
- Parties and instruments involved
- The Philippine National Bank (PNB) sued Ramon Maza and Francisco Mecenas on five promissory notes amounting to P10,000 each.
- Two promissory notes were executed on January 20, 1921, due three months after the date.
- The other three notes were executed on January 21, 1921, due four months after date.
- Each note contained a promise to pay the amount jointly and solidarily to PNB at Ilolio with interest.
- Failure to pay and accrued obligations
- Maza and Mecenas failed to pay the notes at maturity.
- As of September 22, 1924, the total amount due including back interest amounted to P65,207.73.
- Proceedings and defenses
- PNB filed an action before the Court of First Instance of Iloilo to recover the amounts due.
- Defendants’ special defense claimed:
- The notes were sent in blank by Enrique Echaus, who requested the defendants to sign them to enable him to negotiate in case of need.
- Defendants did not negotiate nor received value for the notes nor delivered them for any preexisting debt payment.
- Echaus was the real party in interest and liability.
- Defendants moved to include Echaus as a party, but the trial judge denied this motion.
- Judgment and appeal
- The court rendered judgment for PNB against Maza and Mecenas jointly and severally with interest and costs.
- Defendants appealed, assigning four errors including the denial to make Echaus a party and issues on the merits based on their special defense.
Issues:
- Whether Enrique Echaus was an indispensable party and should have been joined in the case.
- Whether Maza and Mecenas are liable on the promissory notes despite claiming they signed the notes as accommodation parties who received no value.
- Whether defendants can be held liable even though they did not negotiate the notes nor received value for them.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)