Heirs of Tan Uy vs. International Exchange Bank

What is the full case title and citation for this February 13, 2013 decision?

Heirs of Tan Uy vs. International Exchange Bank, G.R. No. 166282, February 13, 2013.

Loan Accommodations What was the amount and nature of the credit granted to Hammer Garments Corporation?

Approximately ₱25 million under an omnibus credit line evidenced by promissory notes and assignments.

Collateral and Sureties What security was provided for Hammer's loans and who were the alleged individual sureties?

Goldkey executed a real estate mortgage; Manuel Chua and Fe Tan Uy allegedly signed sureties.

Default and Foreclosure What was the deficiency amount left after iBank foreclosed on the mortgaged properties?

Hammer defaulted and the foreclosure left a deficiency of ₱13,420,177.62 due to the bank.

Fe Tan Uy’s Defense On what grounds did Fe Tan Uy deny liability for the corporate debt of Hammer?

She claimed she never signed the surety agreement and that her signature was forged.

Goldkey’s Defense How did Goldkey Development Corporation attempt to avoid liability for the deficiency?

It asserted it was a separate corporation and merely a third-party mortgagor for the debt.

RTC and CA Decisions How did the lower courts rule regarding the liability of the corporate and individual defendants?

Both courts pierced the corporate veil and held all defendants jointly and severally liable.

Main Legal Issues What were the two primary issues concerning Fe Tan Uy’s liability and Goldkey’s corporate status?

Whether Fe Tan Uy was personally liable and if Goldkey was a mere alter ego.

Fe Tan Uy’s Liability Ruling Why did the Supreme Court rule that Fe Tan Uy could not be held personally liable?

No competent proof showed she signed the surety or participated in the loan transaction.

Corporate Officer Rule Does mere share ownership or status as an officer make one liable for corporate debts?

No, status as an officer does not automatically make one liable for corporate obligations.

Piercing the Corporate Veil Why was piercing the corporate veil held proper as to Goldkey Development Corporation?

Goldkey was a mere alter ego, sharing owners, directors, and assets with Hammer Garments.

Final Solidary Liability Which entities and individuals were ultimately held jointly and severally liable for the deficiency?

Hammer Garments Corporation, Manuel Chua Uy Po Tiong, and Goldkey Development Corporation are liable.

Absolution of Heirs What was the final status of Fe Tan Uy’s heirs in the Supreme Court decision?

Fe Tan Uy and her heirs were absolved from all liability regarding the corporate debt.