Lex Rex Ph

Albenson Enterprises v. CA Digest

(Note: Albenson not Abenson)


We all have rights but it doesn’t mean we are to abuse our rights to step on to other’s rights.

We may all act within our law-given rights, but if we act intentionally in bad faith against someone in business, we will be liable for Articles 19, 20, 21 of the NCC.


Persons: Human Relations
Negligence towards Business Conduct
Failure to Act in Good Faith
Civil Code Article 19, 20, 21


In 1980, Albenson delivered to Guaranteed Inc., mild steel plates worth P2,575. 

The latter issued a check No. 136361 worth P2,575 to be drawn against E.L. Woodworks, but the bank rejected it saying it is “Account Closed.” Albenson traced the check back to “Eugenio Baltao”. Department of Trade informed that EL Woodwork is registered to Eugene Baltao. The bank also confirmed signature comes from the same person. 

In 1983, Albenson filed a case against Eugenio Baltao, on the grounds of Batas Pambansa 22, “issuing checks without funding.” Fiscal Sumaway reported that Baltao failed to submit counter evidence.

In 1984, CA Fiscal Castro reversed Sumaway’s decision, acquitted Baltao for the reasons that there were no sufficient investigation, no notification to Baltao. The former castigated the latter for careless filing and judicial conduct.

Because of the unjust filing, Baltao filed to RTC of QC moral damages against Albenson. Balto veered that Albenson’s error is erroneous tracing and thereby causing damages to the father of Baltao. RTC of QC decided in favor of Baltao. CA reduced/modified the amounts.


Whether or not the motion of Albenson Enterprises was an abuse of rights which deprived Baltao of the right to hearing.


Supreme Court ruled that Baltao failed to observe the standards set forth by Civil Code Article 19 on the performance of duties, which is, “to act with justice.”

The root issue in the case revolves around Articles 19, 20, 21 of the Civil Code where the law mandates for every person to “give everyone his due.”

The misbehavior called “negligence” was attributed by the RTC and CA to Albenson, but the SC reversed it and attributed “negligence” to Baltao. It was Baltao who first  failed to clarify against Albenson that there are multiple of them that have synonymous names. It appears that BALTAO or the BALTAO’s DID NOT ACT in GOOD FAITH, furthermore, it appears they are performing a synchronous, organized scheme of intentional negligence towards business and honesty. 

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