Case Summary (G.R. No. 69078)
Factual Background
The private respondents are textile manufacturing companies that entered into obligations to purchase capital machinery required for their business integration projects. In December 1949, the Central Bank issued Circular No. 20, which imposed restrictions on foreign exchange sales, later adjusted to favor the integration of local textile mills. By following a series of resolutions, the Central Bank originally permitted these corporations to procure foreign exchange at the preferred rate of P2.00 to US $1.00 for their importation needs.
Legal Proceedings
On January 2, 1964, the private respondents filed a complaint for declaratory relief, seeking confirmation of their rights to purchase foreign exchange from the Central Bank at the preferred rate and to be compensated for the increased financial burdens due to changes in the exchange rate policy. The trial court ruled in favor of the respondents on December 3, 1973, confirming their rights and ordering the Central Bank to pay the respondents specific amounts that were due, along with interest.
Appeals and Intermediate Appellate Court Ruling
The Central Bank appealed the decision, which was later modified by the Court of Appeals on October 19, 1984. The appellate court affirmed most of the trial court’s findings but adjusted the date from which interest on the amounts would accrue, stating it should begin from the date of filing of the original complaint.
Enforceability of Foreign Exchange Transactions
The central issue was whether the Central Bank made an enforceable promise to sell foreign exchange at the preferred rate. The doctrine of promissory estoppel was applicable in this case. This legal principle posits that if a party makes a promise that another party relies upon to their detriment, the first party may be bound to that promise to avoid injustice.
Central Bank's Policy and Compliance
The records indicate that the Central Bank’s earlier policies required textile mills to integrate and reflected commitments that were intended to facilitate such integrations through favorable foreign exchange arrangements. The directives provided by the Central Bank explicitly influenced the private respondents’ decisions to enter into long-term financial commitments.
Rejection of Central Bank's Defense
The Central Bank argued that no perfected contract existed regarding the foreign exchange allocations, citing a precedent where similar regulatory resolutions did not constitute binding contracts. However, the Court distinguish
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Case Overview
- This case involves the Central Bank of the Philippines (petitioner) seeking to annul the decision made by the then Intermediate Appellate Court (now Court of Appeals).
- The decision upheld the rights of private respondents (textile companies) to purchase foreign exchange from the Central Bank at a preferential exchange rate of P2.00 to US $1.00.
- The Court also mandated the payment of interest at the legal rate on the amounts due to the private respondents from December 21, 1970, until full payment.
Parties Involved
- Petitioner: Central Bank of the Philippines
- Respondents: Artex Development Co., Inc., Eastern Textile Mills, Inc., Central Manufacturing Corp., Pacific Knitting Mills, Inc., and Atlas Textile Development Corporation (collectively referred to as "private respondents").
Factual Background
- Private respondents are domestic corporations engaged in textile manufacturing.
- In December 1949, the Central Bank issued Circular No. 20, restricting foreign exchange sales and licensing all transactions.
- From 1954-1955, the Central Bank's Monetary Board initiated policies to integrate local textile mills to enhance investment and employment.
- The policy was later liberalized due to technical and financial challenges, allowing mills to start with less complex operations.
- The Central Bank approved foreign exchange allocations for the importation of machinery necessary for the integration of textile mills, with applications filed by private respondents.
Legislative and Regulatory Framework
- Republic Act 2609 was approved on July 16, 1959, directing monetary authorit