- Petitioner
- Plaridel Surety & Insurance Company
- Respondent
- Joel Santos y Manalo
- Citation
- G.R. No. 204849
- Court
- Supreme Court
- Division
- First Division
- Decided
- September 14, 2021
Summary
Plaridel Surety & Insurance Company sought to avoid liability on Bail Bond No. JCR (2)-23045 issued to Joel Santos y Manalo, claiming it was fraudulently issued by its agent Julie Sañez. The Supreme Court denied the petition, affirming lower court decisions holding PSIC liable. The Court found that PSIC failed to prove forgery by clear and convincing evidence, despite claiming the bond was fake. Key factors included: Sañez was PSIC's authorized agent at the time; the bond was notarized and enjoyed prima facie presumption of authenticity; PSIC received court notices for four years but failed to contest the bond's validity; and under Civil Code Article 1910, principals are bound by their agents' acts within scope of authority. The case establishes that surety companies cannot easily escape liability on bonds issued by authorized agents without strong proof of fraud.