Case Digest (G.R. No. 173297) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Stronghold Insurance Company, Inc. v. Cuenca, petitioner Stronghold Insurance, a domestic surety insurer, and respondent Manuel D. Marañon, Jr. obtained from the Regional Trial Court of Parañaque City a writ of preliminary attachment on January 26, 1998, conditioned on the posting of a bond in the amount of ₱1,000,000.00. On February 11, 1998, Marañon secured SICI Bond No. 68427 JCL (4) No. 02370 from Stronghold Insurance to cover the attachment against respondents Tomas, Marcelina, and Milagros Cuenca (collectively, “Cuencas”) and Bramie T. Tayactac in Civil Case No. 98-023 for collection of money and damages. The sheriff levied on the personal property of Arc Cuisine, Inc., found in its leased commissary in Parañaque, but the assets went missing while under supposed safekeeping. The Cuencas and Tayactac moved to dismiss and quash the attachment for lack of jurisdiction, which the RTC denied. The Court of Appeals annulled the denial for grave abuse of discretion, dismissed t Case Digest (G.R. No. 173297) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- In January 1998, Manuel D. Marañon, Jr. filed Civil Case No. 98-023 in the Regional Trial Court (RTC) of Parañaque City against Tomas, Marcelina and Milagros Cuenca (the Cuencas) for collection of money and damages, and applied for a writ of preliminary attachment.
- The RTC conditioned issuance of the writ on posting a bond of ₱1,000,000.00. On February 11, 1998, Marañon posted SICI Bond No. 02370 issued by Stronghold Insurance Company, Inc. (Stronghold Insurance), and the writ issued two days later.
- The sheriff levied on equipment, supplies and other personal property belonging to Arc Cuisine, Inc., found in its leased commissary premises.
- Procedural History
- February–September 1998: The Cuencas and Bramie T. Tayactac moved in the RTC to dismiss and quash the attachment for lack of jurisdiction (intra-corporate dispute before the SEC). The RTC denied the motions; on certiorari the Court of Appeals (CA) in SP No. 49288 annulled the RTC orders and dismissed Marañon’s amended complaint for lack of jurisdiction.
- December 1999–2000: The CA remanded for hearing on damages. The sheriff reported in February 2000 that the levied properties were missing. The Cuencas and Tayactac moved for delivery of properties and payment under the bond, claiming ₱1,721,557.20 in actual damages plus moral, exemplary damages and attorney’s fees. Stronghold Insurance and Marañon opposed.
- April 28, 2003: The RTC rendered judgment holding Marañon and Stronghold jointly and solidarily liable to pay:
- ₱1,000,000.00 (bond amount)
- ₱100,000.00 moral damages
- ₱50,000.00 exemplary damages
- ₱100,000.00 attorney’s fees
- costs of suit
- 2006: The CA (CV No. 79145) affirmed; Stronghold’s motion for reconsideration denied. Stronghold filed a petition for review on certiorari with the Supreme Court.
Issues:
- Whether the Cuencas and Tayactac, as stockholders of Arc Cuisine, Inc., are the real parties in interest entitled to claim and recover damages under the attachment bond for wrongful attachment of corporate assets.
- Whether Stronghold Insurance and Marañon are jointly and solidarily liable for damages beyond the bond amount, including moral and exemplary damages, attorney’s fees and costs.
- Whether Stronghold Insurance may invoke an indemnity agreement with Marañon to limit or shift its liability.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)