Title
Banco De Oro vs. Equitable Banking Corp.
Case
G.R. No. 74917
Decision Date
Jan 20, 1988
A bank is held liable for reimbursing a payee after issuing crossed checks with forged endorsements, as the court rules in favor of the respondent and emphasizes the importance of upholding principles of estoppel and the duty of diligence on the part of the collecting bank.
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Case Digest (G.R. No. 74917)

Facts:

  • The case involves Banco De Oro Savings and Mortgage Bank (petitioner), Equitable Banking Corporation (respondent), Philippine Clearing House Corporation (PCHC), and the Regional Trial Court of Quezon City, Branch 92.
  • The dispute concerns six crossed Manager's checks issued by Banco De Oro in March, April, May, and August 1983, totaling PHP 45,982.23, payable to Visa Card member establishments.
  • These checks were deposited by Aida Trencio with Equitable Banking Corporation.
  • Equitable stamped the checks with "All prior and/or lack of endorsement guaranteed" and sent them for clearing through PCHC.
  • Banco De Oro paid the checks, debiting its clearing account and crediting Equitable's account.
  • Banco De Oro later discovered the endorsements on the checks were forged and sought reimbursement from Equitable.
  • Equitable refused reimbursement, leading to arbitration under PCHC rules.
  • The Arbiter ruled in favor of Banco De Oro, ordering Equitable to reimburse the amount with interest and attorney's fees.
  • The PCHC Board of Directors and the Regional Trial Court of Quezon City affirmed the Arbiter’s decision.
  • Banco De Oro filed a petition for review with the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court dismissed the petition for lack of merit.
  • The decision of the Regional Trial Court of Quezon City, which upheld the PCHC's ruling, was af...(Unlock)

Ratio:

  • Jurisdiction: The PCHC had jurisdiction as its rules and regulations apply to both negotiable and non-negotiable checks.
  • Interpretation: The term "check" in the PCHC's Articles of Incorporation and Clearing House Rules includes all types of checks used in commercial and banking operations.
  • Estoppel: Banco De Oro was estopped from denying liability because it had stamped its guarantee on the checks, thereby assuming the liabilities of an endorser.
  • Forged Endorsements: The collecting bank (Equitable) generally suffers the loss in cases of...continue reading

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