Case Digest (G.R. No. 269745) Core Legal Reasoning Model
Facts:
This case involves George Rebujio, the petitioner, and Dio Implant Philippines Corporation (DIPC), represented by Ronaldo Candido S. Kalaw, the respondent. On or before August 10, 2016, Rebujio, as the finance officer and authorized signatory of Beverly Hills Medical Group, Inc. (BHMGI), issued Security Bank postdated check No. 0000072006 dated September 7, 2016, payable to DIPC amounting to PHP 279,051.86. The check was intended as payment for merchandise. However, when presented for payment, the check was dishonored due to insufficient funds (DAIF). DIPC filed a complaint for violation of Batas Pambansa Bilang 22 against Rebujio, alleging that he knowingly issued a check without sufficient funds. Despite Rebujio’s plea of not guilty, the Metropolitan Trial Court acquitted him of the crime on reasonable doubt but held him civilly liable to pay the value of the dishonored check, plus legal interest and costs. Upon appeal, the Regional Trial Court reversed the decision, stating
... Case Digest (G.R. No. 269745) Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner: George Rebujio (then finance officer of Beverly Hills Medical Group, Inc. or BHMGI).
- Respondent: Dio Implant Philippines Corporation (DIPC), represented by Ronaldo Candido S. Kalaw.
- Transaction and Issuance of Check
- In August 2015, BHMGI, through dentist Dr. Maria Theresa Mendoza, purchased dental and cosmetic surgery merchandise from DIPC.
- DIPC received Security Bank Check No. 0000072006 amounting to PHP 297,051.86 from BHMGI, drawn on BHMGI’s account and signed by George Rebujio as authorized signatory.
- Upon presentation for payment at Metrobank, the check was dishonored due to insufficient funds ("DAIF" - Depository Account Insufficient Funds).
- Subsequent Follow-Up and Legal Action
- DIPC informed BHMGI’s accountant, Christine Millares, about dishonor; meetings were held with the spouses Rebujio, who acknowledged the debt but later ceased communication.
- DIPC filed a criminal complaint against George Rebujio for violation of Batas Pambansa Bilang 22 (BP 22 - anti-bouncing checks law).
- Defense of Rebujio
- Rebujio claimed the check was wrongfully issued because DIPC was not a BHMGI supplier.
- Dr. Mendoza supposedly purchased items in her personal capacity and did not have authority to transact on behalf of BHMGI.
- BHMGI reprimanded Dr. Mendoza for her conduct.
- Trial Court’s Decision (Metropolitan Trial Court)
- Acquitted Rebujio from criminal charges due to reasonable doubt, especially as it was not proven that Rebujio personally received the notice of dishonor.
- Held Rebujio civilly liable to pay the value of the dishonored check plus legal interest and costs.
- Basis: BP 22 allows recovery of the value of the dishonored check from the person who signed the check.
- Regional Trial Court's Decision
- Reversed the trial court, holding that Rebujio may only be civilly liable if found criminally liable.
- Left open the right of DIPC to institute a separate civil action against BHMGI for recovery.
- Denied reconsideration.
- Court of Appeals Decision
- Reinstated the trial court decision, holding Rebujio civilly liable to pay the check’s value.
- Found Rebujio not a corporate officer (finance officer not included in BHMGI’s by-laws or Corporation Code section enumerations).
- Emphasized issuer’s admission of signing the check.
- Denied motion for reconsideration.
- Supreme Court Petition
- Rebujio argues:
- A corporate officer is liable only if convicted under BP 22 (citing Pilipinas Shell Petroleum Corporation v. Duque).
- Court of Appeals' narrow definition of corporate officers contradicts jurisdictional precedents.
- The term “corporate officer” under BP 22 should include any authorized signatory.
- DIPC contends:
- Rebujio admitted to negligence and the managerial role justifies liability.
- Rebujio is not a corporate officer under the Corporation Code.
- The amount relates to Dr. Mendoza’s personal obligation.
- Rebujio improperly uses the corporate veil to evade liability.
Issues:
- Whether or not George Rebujio, as finance officer and signatory for BHMGI, can be held civilly liable for the value of the dishonored check despite his acquittal from criminal liability under Batas Pambansa Bilang 22.
- Whether the definition of "corporate officer" under BP 22 should be limited to those enumerated in the Corporation Code/by-laws or extended to all authorized signatories of the corporation's checks.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)