Case Summary (G.R. No. 205810)
Background of the Case
IICI, a non-life insurance company, entered into a General Agency Agreement (GAA) with FGE Insurance Management on April 22, 2005. Under this agreement, Enriquez was designated as the general agent authorized to solicit non-life insurance, including bonds. Subsequently, he was appointed as the Operations Manager for Judicial Bonds, with authority to issue bonds up to a maximum of ₱100,000. In a criminal case against Rosita Enriquez, accused of illegal possession of drugs, the bail bond amounting to ₱200,000 was posted but later forfeited when the accused failed to appear in court.
Events Leading to the Forfeiture
Following the accused's non-appearance, Judge Fonacier issued an Order on May 31, 2010, declaring the bail bond forfeited. Despite failing to produce the accused in court and notifying the relevant authorities of Enriquez's revoked authority, IICI filed a motion to lift the forfeiture order and to have the bond declared void due to several alleged irregularities.
RTC's Ruling
Judge Fonacier denied IICI's motion on January 24, 2011, arguing that proper procedural requirements were not met, including the absence of the necessary circumstances to cancel the bond as stipulated in the Revised Rules on Criminal Procedure. Judge Fonacier highlighted that the Clerk of Court's actions concerning the bond issued by Enriquez would be presumed regular unless established otherwise.
Court of Appeals' Ruling
Upon IICI's ensuing petition for certiorari, the Court of Appeals found that Judge Fonacier had committed grave abuse of discretion, identifying multiple defects in the bail bond including the unauthorized increase in the bail amount and procedural deficiencies in bond execution. The CA thus granted IICI's petition and ordered the reversal of the RTC's decision.
Supreme Court's Decision
In reviewing the CA's decision, the Supreme Court overturned its ruling, determining that Judge Fonacier had not exceeded his jurisdiction or abused his discretion. The Court stressed that IICI had sufficient knowledge of the bond's validity and failed to act in a timely manner
...continue readingCase Syllabus (G.R. No. 205810)
Background of the Case
- The People of the Philippines, represented by the Office of the Solicitor General (OSG), filed a petition for review on certiorari concerning a decision made by the Court of Appeals (CA) regarding Judge Albert R. Fonacier of the Regional Trial Court (RTC), Malolos City.
- The CA's decision dated April 10, 2015, and the resolution dated February 4, 2016, were challenged, asserting that Judge Fonacier had committed grave abuse of discretion by denying the motion to lift and recall a forfeiture order concerning a bail bond issued by Industrial Insurance Company, Inc. (IICI).
Parties Involved
- Petitioner: People of the Philippines
- Respondent: Industrial Insurance Company, Inc. (IICI)
Facts of the Case
- IICI, a non-life insurance company, entered into a General Agency Agreement (GAA) with FGE Insurance Management, owned by Feliciano Enriquez (Enriquez), which authorized Enriquez to act as IICI's general agent for soliciting non-life insurance and bonds.
- Enriquez was also appointed as Operations Manager for Judicial Bonds, with the authority to issue bonds in criminal cases up to P100,000.00.
- In Criminal Case No. 2245-M-2006, accused Rosita Enriquez posted a bail bond in the amount of P200,000.00, which was signed by Enriquez and approved by Judge Herminia Pasamba.
- IICI revoked Enriquez's authority on July 7, 2008, due to his failure to remit