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    OC (48) Philippine National Bank v. Teves - CHING

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    The Supreme Court ruled that emergency notes issued by Commonwealth officers in unoccupied areas before President Quezon left the Philippines in 1942 were valid and legal tender. The case involved promissory notes signed by Juan Teves in 1942 payable to the Philippine National Bank, with the consideration paid in emergency notes. While some refused to accept the emergency notes, and part were destroyed in a fire, the Court held this did not invalidate the promissory notes or the Bank's right to payment, as the emergency notes were valid legal tender at the time. The Court affirmed Teves' obligation to pay the Bank.

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    OC (48) Philippine National Bank v. Teves - CHING

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    achi
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    The Supreme Court ruled that emergency notes issued by Commonwealth officers in unoccupied areas before President Quezon left the Philippines in 1942 were valid and legal tender. The case involved promissory notes signed by Juan Teves in 1942 payable to the Philippine National Bank, with the consideration paid in emergency notes. While some refused to accept the emergency notes, and part were destroyed in a fire, the Court held this did not invalidate the promissory notes or the Bank's right to payment, as the emergency notes were valid legal tender at the time. The Court affirmed Teves' obligation to pay the Bank.

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    OC (48) Philippine National Bank v. Teves_CHING

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    The Supreme Court ruled that emergency notes issued by Commonwealth officers in unoccupied areas before President Quezon left the Philippines in 1942 were valid and legal tender. The case involved promissory notes signed by Juan Teves in 1942 payable to the Philippine National Bank, with the consideration paid in emergency notes. While some refused to accept the emergency notes, and part were destroyed in a fire, the Court held this did not invalidate the promissory notes or the Bank's right to payment, as the emergency notes were valid legal tender at the time. The Court affirmed Teves' obligation to pay the Bank.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    163 views1 page

    OC (48) Philippine National Bank v. Teves - CHING

    Uploaded by

    achi
    The Supreme Court ruled that emergency notes issued by Commonwealth officers in unoccupied areas before President Quezon left the Philippines in 1942 were valid and legal tender. The case involved promissory notes signed by Juan Teves in 1942 payable to the Philippine National Bank, with the consideration paid in emergency notes. While some refused to accept the emergency notes, and part were destroyed in a fire, the Court held this did not invalidate the promissory notes or the Bank's right to payment, as the emergency notes were valid legal tender at the time. The Court affirmed Teves' obligation to pay the Bank.

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    © All Rights Reserved
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    of 1

    EMERGENCY NOTES WERE THEN VALID AND LEGAL TENDER

    Doctrine: “Emergency Notes”, referring to the currency which the officers of the Commonwealth in
    unoccupied areas were authorized to issue by President Quezon before he left the Philippines in 1942
    were then valid and legal tender.  (Philippine National Bank v. Teves, G.R. Nos. L-8706 & L-8813;
    December 14, 195)

    x—————x

    EMERGENCY NOTES WERE THEN VALID AND LEGAL TENDER

    Philippine National Bank v. Teves


    G.R. Nos. L-8706 & L-8813, December 14, 1951
    Concepcion, J.

    FACTS:
    In these two appeals, petitioner Philippine National Bank (PNB) and defendant Juan L. Teves
    (Teves) challenge the CFI decision in a civil case, which held that defendant is bound to comply with
    the obligation set forth in the promissory notes. Both parties have appealed from said decision and the
    questions for determination by this Court, stating that: “(1) Teves to pay to the PNB, thru the latter’s
    Negros Oriental Agency with office in Dumaguete City, the following amounts: One thousand four
    hundred eighty-nine pesos (P1,489.00) in full payment of the loan of P3,130.00 released in emergency
    notes; (xxx) in accordance with the promissory notes signed by Teves; (xxx)”

    Teves testified that the consideration for his aforementioned promissory notes was paid to him
    by the PNB in emergency currency, which the people in the mountains, where he and his family
    stayed, for some time, refused to receive, and that part of said notes were destroyed, when his house
    was consumed by his fire.

    This notwithstanding, lower court ruled that Teves is bound to comply with the obligation set
    forth in said promissory notes. Indeed, his promissory note for P2,235.00, is dated April 23, 1942. His
    other promissory note for P895.00, is dated May 18, 1942. At that time, the province of Negros
    Oriental was still unoccupied by the Japanese, who landed therein on May 26, 1942. Hence, it is not
    claimed that the amounts represented by said promissory notes were paid by PNB in Japanese
    Military notes. What is more, Teves himself testified that said payment was made in “emergency
    notes”, referring to the currency which the officers of the Commonwealth in unoccupied areas were
    authorized to issue by President Quezon before he left the Philippines in 1942.

    ISSUE:
    Whether the emergency notes received by Teves from PNB were valid and legal tender?

    HELD:
    Yes, said emergency notes were then valid and legal tender.

    That these so-called ‘Emergency Notes’ were valid and can be implied further from the fact
    that immediately after liberation, the President of the Commonwealth issued an Executive Order No.
    25, dated November 18, 1944, which prohibited the further use and circulation of such kind of ‘notes’
    from said date. Moreover, the fact that the government redeemed such ‘Emergency Notes’ under the
    provisions of Republic Act no. 369 in relation to Republic Act No. 22, is additional proof that the said
    ‘Notes’ were considered as legal tender at the time that they were printed and issued.”

    The alleged refusal of some people to receive said emergency notes from the Teves and the
    alleged destruction thereof, while in his possession, by fire, affects neither the validity of the
    promissory notes in question, nor PNB’s right to demand payment thereof. Teves’ obligation was
    therefore not extinguished.

    Hence, Teves must pay PNB as the emergency notes received by him were then valid and
    legal tender.

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