Ernestina Crisologo-Jose v. Court of Appeals

Summary

This case involved a dispute over a dishonored corporate check where Ricardo Santos, Jr., vice-president of Mover Enterprises, Inc., co-signed as accommodation for his president's personal obligation to Ernestina Crisologo-Jose. When the P45,000.00 check bounced, Santos attempted to pay via cashier's check, which Jose refused, prompting him to consign the amount with the court. The Supreme Court held that Santos was personally liable as an accommodation party since corporate accommodation instruments are ultra vires, and that consignation was proper given the creditor-debtor relationship created by the dishonored check. However, the Court criticized the Court of Appeals for improperly addressing the merits of the related criminal case under BP 22, emphasizing the distinction between civil and criminal proceedings.