Title
Rebuldela vs. Intermediate Appellate Court
Case
G.R. No. 74696
Decision Date
Nov 11, 1987
Calderon purchased LBC, later sued sellers for undisclosed tax liabilities, alleging fraud. Courts ruled against him, citing lack of evidence, wrongful attachment, and liability for damages.
A

Case Summary (G.R. No. 74696)

Facts of the Case

On November 2, 1976, Calderon purchased the Luzon Brokerage Corporation (LBC) and its five affiliated companies from the private respondents. Shortly thereafter, the Bureau of Customs suspended LBC's operations due to unpaid customs taxes and duties amounting to P1,475,840.00 incurred prior to the sale. To lift this suspension, Calderon paid P606,430.00. Subsequently, on October 27, 1977, Calderon filed a complaint against the private respondents, seeking recovery of the customs amount and claiming damages based on allegations of willful concealment of liabilities by the respondents. Calderon petitioned for a preliminary attachment of the respondents' properties, asserting fraudulent intent on their part. The trial court allowed the attachment, leading to the garnishment of the respondents' bank accounts.

Private Respondents’ Defense

The private respondents contended that the customs duties owed were part of the transactions managed by Calderon after he took control of LBC. They argued that he had been informed of the outstanding liabilities during negotiations and maintained that all accounting records were properly documented. To counter Calderon's claims, the respondents filed a counterbond to discharge the writ of attachment, which was granted by the trial court, resulting in the release of their assets.

Court of Origin and Appellate Review

After a trial, the Regional Trial Court ruled against Calderon, finding both him and his surety, First Integrated Bonding and Insurance Company, jointly and severally liable for damages incurred by the private respondents due to the wrongful attachment. This decision was partially modified upon appeal, reducing the awarded moral and exemplary damages but upholding the ruling that the preliminary attachment was maliciously sued out.

Findings of the Appellate Court

The Appellate Court noted that Calderon failed to substantiate his claims against the respondents, primarily failing to provide any evidence supporting his allegations of malice and misconduct. His absence during cross-examination further weakened his position. The appellate ruling emphasized that Calderon did not present any proof to validate his accusations, allowing the findings of the trial court regarding the financial records to stand.

Surety's Liability and Legal Provisions

The surety’s position was that the attachment bond should be extinguished upon the dissolution of the attachment. However, the court clarified that a surety’s liability persists if the attachment was found to be wrongfully issued. The court referenced Section 4, Rule 57 of the Rules of Court, which

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