G.R. No. 136374 - Baluyot vs. Holganza

On May 17, 1948, Acoje Mining Company, Inc. requested the Director of Posts to open a post, telegraph, and money order office at its Sta. Cruz, Zambales mining camp for the convenience of its employees and families.
The Director of Posts conditioned the opening on the company providing free quarters, all essential equipment, and assigning a responsible employee as postmaster without compensation until funds were available.

The company accepted the terms and requested necessary forms for establishing the branch.
On April 1, 1949, the Director of Posts added a requirement: the company must assume pecuniary responsibility for any loss due to dishonesty, carelessness, or negligence by the assigned employee, suggesting a board resolution.
On September 2, 1949, the board of directors passed a resolution “That the requirement of the Bureau of Posts that the Company should accept full responsibility for all cash received by the Postmaster be complied with,” and forwarded it to the Bureau.

The branch office opened on October 13, 1949, with Hilario M. Sanchez—an employee of the company—as postmaster.
On May 11, 1954, Sanchez disappeared on leave; audit revealed a shortage of ₱13,867.24.
After the company failed to pay, the Republic of the Philippines sued on September 10, 1954, before the CFI of Manila for that amount.
The company argued the resolution was ultra vires and, if valid, imposed only guarantor liability after exhausting the principal’s assets; it also challenged the evidentiary support for the claimed loss.

The CFI reduced the claimed loss to ₱9,515.25—the amount supported by evidence—and rendered judgment for the plaintiff accordingly.
It held the board’s resolution valid, not ultra vires, and imposed principal liability on the company rather than guarantor liability.

Whether the board‐adopted resolution assuming full responsibility for the postmaster’s cash receipts was ultra vires.
If deemed ultra vires, whether it was enforceable or void.

Whether the company’s liability under the resolution was that of a principal or merely a guarantor, requiring exhaustion of the principal’s assets.
Whether the amount claimed by the government was supported by the official records.