GR 166405; (August, 2008) (Digest)
G.R. No. 166405 ; August 6, 2008
CLAUDE P. BAUTISTA, petitioner, vs. AUTO PLUS TRADERS, INCORPORATED and COURT OF APPEALS (Twenty-First Division), respondents.
FACTS
Petitioner Claude P. Bautista, as President of Cruiser Bus Lines and Transport Corporation, purchased spare parts from respondent Auto Plus Traders, Inc. and issued two postdated checks as payment. Both checks were subsequently dishonored for insufficiency of funds. Respondent filed a criminal complaint for violation of Batas Pambansa Blg. 22 (B.P. 22). The Municipal Trial Court in Cities (MTCC) granted Bautista’s demurrer to evidence, acquitting him on reasonable doubt but ordering the corporation, through him, to pay the civil liability for the checks. Both parties appealed to the Regional Trial Court (RTC), which modified the MTCC order by directing “the accused” to pay the value of the checks. The Court of Appeals affirmed the RTC decision, holding Bautista personally and civilly liable.
ISSUE
Whether the Court of Appeals erred in upholding the RTC’s ruling that petitioner Claude P. Bautista, as a corporate officer, is personally and civilly liable for the value of the dishonored checks.
RULING
The Supreme Court granted the petition and reversed the Court of Appeals. The Court clarified that the civil liability in a B.P. 22 case is based on the source of obligation, which is the contract for the purchase of spare parts. The checks were issued to cover a corporate debt. The Court found that both checks were corporate checks, not personal checks of Bautista. One check was explicitly drawn against the corporation’s account, and the other, while bearing Bautista’s printed name, was also a corporate check as indicated by the account name “Cruiser Bus Lines and Transport Corporation” on its face. Consequently, the obligation is corporate. The separate juridical personality of the corporation shields its officers from personal liability for corporate debts, unless grounds for piercing the corporate veil are established, which were absent here. The acquittal in the criminal case did not automatically extinguish the civil liability, but such liability pertains to the corporation, not Bautista personally. The dismissal of the criminal cases is without prejudice to the filing of a proper civil action against the corporation.