Facts:

The case involves Allied Banking Corporation (now Philippine National Bank) as the petitioner and Elizabeth Sia as the respondent. The events unfold in Cebu City, stemming from a dispute over bank account access following the death of See Sia, Elizabeth’s father. Elizabeth had two accounts with the now-defunct Orient Commercial Banking Corporation: Account No. 023190001020—solely under her name—and a joint account (Account No. 023190001031) with her father. At the time of the bank's closure on October 15, 1998, their combined uninsured deposits totaled PHP 5,228,883.71. Allied Bank assumed the unpaid deposit liabilities of Orient Bank with the help of the Philippine Deposit Insurance Corporation (PDIC).

On December 13, 1999, Elizabeth's father executed a Special Power of Attorney (SPA) permitting Elizabeth to manage claims regarding the deposits and also authorized her to transfer these claims to Allied Bank. The same day, Elizabeth and Allied Bank executed a Deed of As

...

Facts:

Background and Banking Relationships

• Private respondent Elizabeth Sia maintained two bank accounts with the now defunct Orient Commercial Banking Corporation (Orient Bank):
• Account No. 023190001020 – solely in her name.
• Account No. 023190001031 – a joint “and/or” account with her father, See Sia.
• At the time of Orient Bank’s closure on October 15, 1998, these accounts held uninsured deposits amounting to P5,228,883.71.

Assignment of Claims and Creation of the Allied Bank Account

• On December 13, 1999, See executed a Special Power of Attorney authorizing Elizabeth to claim payment from the Philippine Deposit Insurance Corporation (PDIC) for the deposits in Orient Bank Account No. 023190001020 and to assign his claim to Allied Bank.
• On the same day, Elizabeth and Allied Banking Corporation (now Philippine National Bank) executed a Deed of Assignment whereby:
• A portion of the uninsured deposits (P4,470,825.22) was assigned to Allied Bank.
• Allied Bank agreed to pay this amount in installments—20% within one week and the remaining balance in equal annual amortizations over five years.
• To facilitate these payments, SA No. 0570231382 was opened in Allied Bank at the Fuente OsmeAa Branch in Cebu City, exclusively under Elizabeth’s name, and she was issued Passbook No. SAL 782654-AB.

Notification of Death and Subsequent Freezing of the Account

• On December 14, 2000, Allied Bank received a letter from Atty. Rolando M. Lim, representing the heirs of See Sia, informing the bank of See’s death on May 4, 2000 and requesting that all transactions relating to See’s account be suspended pending settlement of his estate.
• In response, Allied Bank froze all transactions on SA No. 0570231382, which consequently prevented Elizabeth from making withdrawals.
• On January 3 and 5, 2001, Elizabeth’s attempts to withdraw funds were denied, and on January 15, 2001, Allied Bank formally notified her of the freezing, emphasizing the need for resolution between her and her siblings regarding the estate.

Litigation and Lower Court Decisions

• Elizabeth filed a complaint for specific performance, breach of contract, and damages, arguing that as the sole named depositor on SA No. 0570231382, she was entitled to full access, and that Allied Bank’s actions were both malicious and unfounded.
• The Regional Trial Court (RTC) ruled on January 24, 2005, in her favor:
• Finding that Allied Bank breached its contractual obligations by denying her the right to withdraw.
• Noting that despite the source of the funds being derived from settlements involving both her and her father, the savings account was exclusively in her name.
• Ordering Allied Bank to release the funds and award various damages (including attorney’s fees, litigation expenses, actual, moral, exemplary, and nominal damages).
• Allied Bank’s subsequent motion for reconsideration was denied by the RTC on April 22, 2005, after which Allied Bank appealed to the Court of Appeals (CA).
• The CA Decision dated December 16, 2009, affirmed with modifications the RTC’s ruling, specifically:
• Confirming that SA No. 0570231382 pertains exclusively to Elizabeth based on the Passbook evidence.
• Reducing the quantum of damages awarded as being grossly exorbitant.
• Allied Bank’s further motion for reconsideration was again denied by the CA in its Resolution dated January 12, 2011.

Core Factual Controversy

• Elizabeth contended that the account, being solely in her name, should not be subject to any freezing upon her father’s death.
• Allied Bank maintained that the Deed of Assignment and the source of the funds revealed a joint ownership with her father, thereby justifying the temporary freezing of the account pending the settlement of the conflicting claims.
• Both the trial and appellate courts found that the factual record—supported by the bank records and the Deed of Assignment—demonstrated that part of the funds originated from her father’s share, despite the account’s title.

Issue:

Whether Allied Bank had a legal basis to temporarily freeze SA No. 0570231382 upon receipt of notice of See Sia’s death.

• The dispute centers on whether the bank’s action was justified given that the savings account, although solely in Elizabeth’s name, contained funds derived from both her and her father.

Whether the determination that the savings account is exclusively Elizabeth’s is correct despite evidence suggesting joint deposit origins.

• Allied Bank argues that the Deed of Assignment and the nature of the funds indicate shared ownership with See Sia.
• Elizabeth insists that the account’s title as solely her name eliminates any legal basis for freezing the account based on her father’s death.

Whether the appellate courts erred in reviewing a matter that involves questions of legal interpretation instead of factual disputes, in light of Rule 45 of the Revised Rules of Civil Procedure.

• Elizabeth contends that the issues, being factual, should not have been considered under a petition for review on certiorari.
• The case thus raises the broader issue of distinguishing between questions of law and questions of fact in the context of bank account freezes upon a depositor’s death.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)