Case Digest (G.R. No. 89252) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On 9 February 1981, Raul Sesbreno (petitioner) placed ₱300,000.00 for 32 days with Philippine Underwriters Finance Corporation (Philfinance), Cebu Branch. Philfinance issued him a Certificate of Confirmation of Sale “without recourse” of one Delta Motors Corporation Promissory Note No. 2731 due 6 April 1981 at 17% per annum, a Certificate of Securities Delivery Receipt reflecting custodianship by Pilipinas Bank (DCR No. 10805), and post-dated checks totaling ₱304,533.33 payable on 13 March 1981. When Sesbreno presented the checks on maturity, they were dishonored for insufficient funds. On 26 March 1981, he received from Pilipinas Bank the DCR, which confirmed that the note was held in custody and promised physical delivery upon his written instruction. Sesbreno demanded delivery on 2 April, 3 July, and 3 August 1981, but Pilipinas Bank refused, referring him to Philfinance. He also notified Delta Motors Corporation of his partial assignment (₱307,933.33) of the promissory note, Case Digest (G.R. No. 89252) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Money market placement and related instruments
- On February 9, 1981, petitioner Raul Sesbreno placed ₱300,000.00 with Philippine Underwriters Finance Corporation (Philfinance), maturing on March 13, 1981.
- Philfinance issued simultaneously:
- Certificate of Confirmation of Sale “without recourse” for Delta Motors Corporation Promissory Note (DMC PN) No. 2731 (32-day term, 17% p.a.).
- Certificate of Securities Delivery Receipt (DCR) No. 10805, indicating custody by Pilipinas Bank.
- Post-dated checks totaling ₱304,533.33, payable March 13, 1981.
- On March 13, the checks were dishonored; on March 26, petitioner received DCR No. 10805 from Pilipinas Bank showing custody of DMC PN 2731 (face value ₱2,300,833.34, “non-negotiable,” maturity April 6, 1981).
- Demand for physical delivery and banking response
- Petitioner demanded delivery of the original note via letters dated April 2, July 3, and August 3, 1981; Pilipinas Bank deferred to Philfinance for instructions and did not deliver.
- Petitioner also demanded partial satisfaction from Delta Motors (note assigned to him to the extent of ₱307,933.33); Delta denied liability, citing prior offset against its PN No. 143-A.
- Philfinance was placed under joint SEC/Central Bank management; the promissory note remained with SEC.
- Judicial proceedings
- On September 28, 1982, petitioner sued Pilipinas Bank and Delta Motors for damages in the RTC, Branch 21, Cebu City.
- RTC dismissed the complaint on August 5, 1987; Court of Appeals affirmed on March 21, 1989, holding Philfinance solely liable but not impleaded.
- Petitioner’s motions for reconsideration were denied, leading to this petition for review on certiorari before the Supreme Court.
Issues:
- Recovery from Delta Motors Corporation
- Whether petitioner, as assignee of a portion of a “non-negotiable” promissory note, can enforce payment against the maker Delta Motors.
- Liability of Pilipinas Bank
- Whether Pilipinas Bank, as custodian under the DCR, is solidarily liable to pay the assigned portion of DMC PN No. 2731.
- Corporate veil
- Whether the separate corporate personalities of Philfinance, Delta Motors, and Pilipinas Bank should be disregarded.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)