- Petitioner
- Citibank
- Respondent
- Hon. Segundino G. Chua
- Citation
- G.R. No. 102300
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Campos, Jr., J.
- Decided
- March 17, 1993
Summary
This Supreme Court case involves a complex dispute between Citibank and the Velez spouses over a banking arrangement worth P5,000,000.00 that operated from 1985-1986. While the spouses claimed it was a legitimate accommodation, Citibank alleged fraudulent use of unfunded checks. The procedural focus centered on whether Citibank was properly represented at pre-trial, with lower courts declaring it in default for inadequate corporate authorization. The Supreme Court reversed, establishing that foreign corporations' by-laws are effective in the Philippines when SEC grants business licenses, and that corporate officers can validly delegate litigation authority without board resolutions when by-laws permit. The decision emphasizes that default orders should be exceptional and that litigants deserve opportunities for trial on the merits rather than dismissal on technicalities, particularly in substantial commercial disputes.