G.R. No. 156262 - Tuazon vs. Heirs of Ramos

The case involves the collection of a sum of money arising from the failure of petitioners to pay respondents' predecessor-in-interest.
Petitioners issued several Traders Royal Bank checks in payment for purchased rice, but these checks bounced due to insufficiency of funds.
Respondents sought to collect payment from petitioners, who indorsed the checks, rather than from the check drawer.

Between May 2 and June 5, 1988, spouses Leonilo and Maria Tuazon purchased 8,326 cavans of rice from the deceased Bartolome Ramos (predecessor-in-interest of respondents).
Only 4,437 cavans were paid for, leaving 3,889 cavans unpaid, with an obligation amounting to P1,211,919.00.
Payment was attempted via several checks issued by a third party (Evangeline Santos), but all checks bounced.
Petitioners were aware of insufficient funds before issuing checks and failed to provide payment despite demands.

Respondents alleged that petitioners conspired with others to defraud creditors by executing simulated or fictitious sales of properties and vehicles to spouses Anastacio and Mary Buenaventura, as well as to co-petitioners Alejandro and Melecio Tuazon.
These simulated sales resulted in cancellation of titles in the names of spouses Tuazon and issuance of new titles favoring the transferees, thereby prejudicing respondents' claims.

Petitioners denied having purchased rice from Bartolome Ramos, claiming that Magdalena Ramos, the deceased's wife, owned and traded the merchandise, and that Maria Tuazon acted only as Magdalena's agent.
They contended that Evangeline Santos was the true buyer and issuer of checks, and that petitioners received these checks in good faith, unaware that the checks were not funded.
Petitioners requested the inclusion of Evangeline Santos as an indispensable party, considering her as primarily liable.
They also rejected allegations of fictitious sales, asserting these sales were bona fide transactions due to financial difficulties prior to the suit.

Civil and criminal cases were filed against spouses Tuazon, later consolidated and amended to include spouses Buenaventura and co-petitioners Alejandro and Melecio Tuazon.
Bartolome Ramos was substituted by his heirs, respondents in this case.
Petitioners moved to file a third-party complaint against Evangeline Santos; the RTC denied this motion.
Petitioners were acquitted in criminal cases but found civilly liable by RTC, with judgment ordering payment of P1,750,050.00 plus attorney's fees, moral damages, and costs of suit.
The Court of Appeals (CA) affirmed the RTC decision, rejecting the agency claim and ruling that Evangeline Santos was not an indispensable party.
Petitioners filed a Petition for Review under Rule 45 of the Rules of Court, contesting the CA decision.

Whether or not the Court of Appeals erred in ruling that petitioners are not agents of respondents.
Whether or not the Court of Appeals erred in rendering judgment against petitioners despite the failure of respondents to include Evangeline Santos as an indispensable party to the suit.