Case Digest (G.R. No. 227095) Core Legal Reasoning Model
Facts:
The case involves the petitioners Trans Industrial Utilities, Inc., Spouses Rodolfo and Victoria Tiu, and Juanita T. Tiu, who are appealing against the Metropolitan Bank & Trust Company (substituted by Meridian Corporation) regarding a collection case for unpaid loans. The events leading to the dispute relate to several loans taken by Trans Industrial from Metrobank, secured by both property and Continuing Surety Agreements signed by the petitioners. Trans Industrial defaulted on its loans, leading to unsuccessful restructuring attempts and a formal debt settlement agreement signed on September 25, 2000.
After defaulting again on the restructured loan, Metrobank filed an action for the collection of sums owed, resulting in the Regional Trial Court (RTC) in Cebu City ruling in favor of Metrobank. Petitioners contested the court’s decision, asserting that the loans exceeded the authority granted in the board resolutions due to alleged limitations, and that the applicable loa
Case Digest (G.R. No. 227095) Expanded Legal Reasoning Model
Facts:
Parties Involved- Petitioners: Trans Industrial Utilities, Inc., Spouses Rodolfo and Victoria Tiu, and Juanita T. Tiu.
- Respondent: Metropolitan Bank & Trust Company (Metrobank), later substituted by Meridian (SPV-AMC) Corporation.
Loan Agreements and Security
- Initial Loans: Rodolfo Tiu, as President of Trans Industrial, applied for and was granted loans by Metrobank.
- Security: A parcel of land covered by TCT No. 38486 was assigned as collateral.
- Continuing Surety Agreements: Petitioners executed two Continuing Surety Agreements (July 8, 1997, and July 3, 1998) to secure the loans amounting to P16,343,800.00 (Philippine Peso loan) and US$626,000.00 (US Dollar loan).
Default and Debt Settlement
- Default: Petitioners failed to pay the obligations at maturity.
- Debt Settlement Agreement: After negotiations, a Debt Settlement Agreement was executed on September 25, 2000, restructuring the loans.
- Dacion En Pago: Trans Industrial executed a Deed of Dacion En Pago on September 26, 2000, transferring a parcel of land (TCT No. 45993) to Metrobank to partially settle the obligations.
- New Surety Agreement: Petitioners executed another Continuing Surety Agreement on September 28, 2000, securing the restructured loan of P34,565,524.98.
Failure to Comply with Restructured Agreement
- Non-Payment: Petitioners again defaulted on the restructured loan, failing to pay monthly amortizations starting November 30, 2001.
- Collection Suit: Metrobank filed a case for the collection of the sum of money.
Petitioners’ Defenses
- Arguments in Amended Answer:
- The authority to borrow was limited to specific amounts (P10,000,000.00 in 1995 and P15,000,000.00 in 1996), and the loans exceeded these limits.
- The loans were denominated in US Dollars but were given in Philippine Pesos.
- The assignment of land valued at P27,500,000.00 was sufficient to settle the loans, making the continuing surety agreements null and void.
- Trans Industrial had overpaid its obligations.
Trial Court Proceedings
- Demurrer to Evidence: Petitioners filed a Demurrer to Evidence, arguing that the loans exceeded the authorized amounts and that Rodolfo Tiu exceeded his authority. The RTC denied the demurrer.
Issues:
- Whether the Secretary's Certificate and Debt Settlement Agreement are valid despite petitioners’ claim of lack of quorum in the board resolution.
- Whether Rodolfo Tiu exceeded his authority by borrowing in US Dollars instead of Philippine Pesos.
- Whether Trans Industrial overpaid its loan obligations.
- Whether the lower courts erred in holding that petitioners failed to substantiate their claim of overpayment.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)