Title
Republic vs. Cloribel
Case
G.R. No. L-27905
Decision Date
Dec 28, 1970
The court declared the trade assistance agreement void due to lack of presidential approval, absence of authority from the NAMARCO General Manager, and the agreement's irrelevance to the compromise accord.
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Case Digest (G.R. No. L-27905)

Facts:

  • The case involves the Republic of the Philippines and the National Marketing Corporation (NAMARCO) as petitioners.
  • Respondents include Hon. Gaudencio Cloribel, Judge of the Court of First Instance of Manila, Jose San Agustin, Ex-Officio Sheriff of the City of Manila, and Bienvenido Y. Aguilar.
  • The original action for certiorari aimed to annul Judge Cloribel's order dated July 5, 1967, in Civil Case No. 38224.
  • The case originated from a petition filed on October 24, 1958, by the Republic and/or the Central Bank against several government officials and Aguilar.
  • The petition sought to prevent the release of goods imported by Aguilar under a Central Bank license, alleging fraudulent importation of commercial coconut oil and other goods, resulting in damages of Six Million Pesos (₱6,000,000.00).
  • After a lengthy trial, the lower court dismissed the petition on July 1, 1965, awarding Aguilar damages totaling ₱815,418.79.
  • An amicable settlement was reached on July 8, 1966, approved by the court on December 2, 1966, which included a Compromise Agreement and a Trade Assistance Agreement allowing Aguilar to import commodities worth up to $15 million.
  • Aguilar later sought to set aside the court's approval of the Compromise Agreement, claiming the Trade Assistance Agreement was integral to the settlement.
  • The court denied Aguilar's petition, leading him to file for execution of the Trade Assistance Agreement, which the petitioners opposed.
  • On July 5, 1967, the respondent Judge issued an order for a writ of execution, prompting the petitioners to file for certiorari.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the petitioners, annulling and setting aside the order of the respondent Judge dated Ju...(Unlock)

Ratio:

  • The Court concluded that the respondent Judge exceeded his jurisdiction by including the Trade Assistance Agreement in the matters to be executed.
  • The Trade Assistance Agreement was not a binding contract as it lacked necessary approval from the President of the Philippines, per Executive Order No. 298, Series of 1940, and Memorandum Circular No. 150, Series of 1955.
  • The General Manager of NAMARCO lacked authority to bind the corporation to the Compromise Agreement, as the Board of Directors only authorized him to enter into a trade assistance agreement, not to sign any compromis...continue reading

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