Alvin Patrimonio v. Napoleon Gutierrez

Summary

This case involves professional basketball player Alvin Patrimonio's challenge to a loan allegedly contracted on his behalf by business partner Napoleon Gutierrez. Gutierrez borrowed P200,000 from Octavio Marasigan using one of Patrimonio's pre-signed blank checks without authorization. The Supreme Court granted Patrimonio's petition, ruling that the loan contract was void for lack of special power of attorney under Civil Code Article 1878. The Court found that Gutierrez exceeded his limited authority to use checks only for business expenses with prior approval, and that Marasigan was not a holder in due course due to his knowledge that Patrimonio was not party to the loan transaction. The decision establishes important precedents on agency authority requirements for borrowing money and the completion of negotiable instruments within authorized limits.