CASE DIGEST: Sumacad v. Province of Samar

 


VIOLET MCGUIRE SUMACAD v. PROVINCE OF SAMAR, GR No. L-8155, 1956-10-23

 

Facts:

In May, 1942, while the province of Samar was still occupied by Japanese military forces, a check was issued by said province to Paulino M. Santos (then the postmaster of Borongan) for the sum of P25,000, drawn against the Philippine National Bank Cebu Branch. The payee negotiated the check with James McGuire, an American citizen and resident of the municipality of Borongan. After the liberation in 1946, James McGuire presented the check to the municipal treasurer of Borongan for payment, but the latter (who merely noted it) was not able or did not choose to pay the same.

James McGuire wrote letters to the Bureau of Posts dated May 28 and August 5, 1948, and March 30, 1950 seeking payment of the check, which were in turn referred by the 'Director of the Bureau of Posts to the Philippine National Bank on April 21, 1950.

On April 25, 1950, the Philippine National Bank requested the Bureau of Posts to furnish it with photostatic copies of the check which were duly received by the bank on May 12, 1950.

On May 14, 1950, the latter requested James McGuire to present the check to the provincial treasurer and the provincial auditor for certification.

On August 22, 1950, James McGuire again requested the Bureau of Posts to expedite compliance with the requirement of the Philippine National Bank so as to permit the encashment of the check. Before the check could be certified by the authorities concerned as being in order and entitled to priority of payment, the province of Samar, on September 4, 1951, withdraw the amount of P83,504.07, leaving a balance of only P743.43. In the meantime, James McGuire transferred his rights to the check to the herein plaintiffs who, unable to cash it, filed the present complaint against the province of Samar and the Philippine National Bank.

After trial the court rendered a decision sentencing the defendants to pay jointly and severally to the plaintiffs the sum of P25,000, plus legal interest.

Issues:

The position of the appellant bank is that it did not issue the check and was merely called upon to pay the same upon being presented for encashment if and when funds for the purpose were available that in any event, the appellant bank cannot be held solidarity liable, the province of Samar being the drawee of the check and therefore primarily liable to pay the same.

Ruling:

But in view of the fact that as early as May 12, 1950, upon its own request, it was furnished with photostatic copies of the check in question; and on May 14, 1950, it went to the trouble of requiring James McGuire to present the check to the provincial treasurer and provincial auditor for necessary certification, it voluntarily assumed the obligation of holding so much of the deposit of the province of Samar as would be sufficient to cover the amount of the check, or before allowing the withdrawal... that exhausted said deposit, of making the necessary inquiry on the matter. In our opinion, an implied acceptance of the check by the appellant bank was thereby created. The request by the appellant bank from the Bureau of Posts for photostatic copies of the check and the subsequent requirement by it for its presentation by James McGuire to the provincial treasurer and the provincial auditor for certification, would be an empty gesture if the appellant did not thereby mean to assume the obligation of paying the check and holding sufficient deposit of the drawer for the purpose. Even so, appellant's resulting obligation is merely subsidiary, the province of Samar being primarily liable to pay the check.


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