Star Two (Spv-Amc) v. Howard Ko

Summary

This case involves a suretyship dispute where Star Two (SPV-AMC), Inc. sued individual sureties who had guaranteed Jianshe Motorcycle Industries' loans to RCBC under a Comprehensive Surety Agreement with a P50 million liability cap. The key issue was whether the sureties, particularly Howard Ko, had already paid amounts exceeding their liability limit. The trial court found sufficient evidence that Howard Ko paid P89,656,002.67 through various modes including certificates of deposit and account debits, exceeding the P50M cap. The Court of Appeals affirmed this finding, and the Supreme Court denied the petition, establishing that documentary evidence can be admitted without formal offer if properly identified and incorporated in records. The case reinforces principles of suretyship under Article 2054 of the Civil Code and demonstrates that once a surety's payments exceed the agreed liability cap, their obligations are extinguished. The decision emphasizes the binding nature of bank documents as evidence of payments made through institutional channels.