Title
Fleischer vs. Botica Nolasco Co., Inc.
Case
G.R. No. 23241
Decision Date
Mar 14, 1925
A shareholder sued Botica Nolasco, Inc. for refusing to register transferred shares, citing by-laws granting preferential purchase rights. The Supreme Court ruled the by-law conflicted with Corporation Law, upheld the shareholder's rights, and deemed mandamus the proper remedy.

Case Summary (G.R. No. 23241)

Factual Background

Manuel Gonzalez was the original owner of five shares of Botica Nolasco, Inc., certificates Nos. 16–20. On March 11, 1923, Gonzalez assigned and delivered those five shares to Henry Fleischer by endorsing the certificates, in consideration of a large sum owed by Gonzalez to Fleischer. On March 13, 1923, Dr. Eduardo Miciano, secretary-treasurer of the corporation, offered on behalf of the corporation to buy the shares at their par value of P100 per share. Article 12 of the by-laws purported to give the corporation a preferential right to acquire shares offered for transfer. Fleischer refused the corporation's offer and requested that the corporation register the shares in his name; Miciano refused, invoking the by-law. On March 13, 1923, Gonzalez delivered a written statement to the corporation requesting that the five shares sold by him not be transferred to Fleischer and acknowledging the corporation's preferential right. On June 14, 1923, Gonzalez attempted to withdraw that written statement, but the corporation replied June 15 that the original statement conformed with the by-laws and that the shares had been registered in the name of the Botica Nolasco, Inc.

Procedural History

The action was instituted August 14, 1923, initially against the board of directors to compel registration of the five shares in Fleischer's name and to recover P500 in damages. A demurrer alleging improper party was sustained, and the plaintiff was permitted to amend. On November 15, 1923, the amended complaint named Botica Nolasco Co., Inc. as defendant and repeated the prayer for registration and P500 damages. The defendant demurred on grounds of insufficiency and ambiguity; the demurrer was overruled and the defendant answered, denying the allegations and asserting as a special defense that Article 12 of the by-laws granted the corporation a preferential right to buy the shares at par plus P90 dividends for 1922, which offer Fleischer refused. The trial court heard the case and, on August 21, 1924, held Article 12 to be in conflict with Act No. 1459, especially Sec. 35, and ordered the corporation to register the shares in Fleischer's name with costs against the defendant. The defendant appealed.

Issue Presented

Whether Article 12 of the by-laws of Botica Nolasco Co., Inc., purporting to give the corporation a preferential right to purchase shares offered by a shareholder, was valid under Act No. 1459, particularly Sec. 13, par. 7 and Sec. 35, and whether the corporation could refuse to register a bona fide transfer to a purchaser for value.

Parties' Contentions

The appellant contended that Article 12 conformed to Act No. 1459 and thereby justified the corporation's refusal to register the transfer; the corporation also argued incidentally that the proper defendants were the president and secretary, who signed and countersigned certificates under Sec. 35. The appellee maintained that he acquired the shares in good faith for valuable consideration, that the by-law was ultra vires as contrary to the Corporation Law, and that the corporation could not defeat his rights as a purchaser who had no notice of any lawful restriction.

Trial Court Ruling

The Court of First Instance, through Judge N. Capistrano, held that Article 12 conflicted with Act No. 1459, especially Sec. 35, and ordered the corporation to register the five shares in the name of Henry Fleischer, with costs assessed against the defendant.

Supreme Court's Legal Reasoning

The Supreme Court analyzed the express powers conferred by Sec. 13, par. 7 to make by-laws "not inconsistent with any existing law" for the transferring of stock, and the definitional and procedural provisions of Sec. 35, which declared that shares "are personal property and may be transferred by delivery of the certificate indorsed by the owner" and that no transfer is valid, except as between the parties, until entered upon the corporate books. The Court observed that Sec. 35 contemplates shares as personal property freely transferable and does not authorize discrimination as to whom they may be sold. The Court concluded that a by-law governing transfers must harmonize with the statutory regimen and must not impose restrictions inconsistent with Sec. 35. The by-law in question created a preferential right in the corporation to acquire shares under the same conditions and thereby imposed a restraint on the alienation of shares that transcended the statutory limits. The Court treated such a restriction as ultra vires, violative of property rights, and a restraint of trade. The Court further held that an unauthorized by-law cannot defeat the rights of a purchaser for value who had no notice of the by-law, citing authorities that an assignee is not bound by such by-law merely by virtue of the assignment and that contractual restrictions unknown to the purchaser do not affect his title. The Supreme Court also rejected the defendant's belated contention that the action should have be

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.