Title
Banco de Oro Universal Bank, Inc., Vivian Duldulao, and Christine Nakanishi vs. Liza A. Seastres and Annabelle N. Benaje
Case
G.R. No. 257151
Decision Date
Feb 13, 2023
BDO held liable for P7.4M unauthorized withdrawals due to negligence, violating banking diligence; Seastres' trust in Benaje not contributory negligence.
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Case Digest (G.R. No. 257151)

Facts:

Background of the Case:
This case involves a Petition for Review on Certiorari filed by Banco de Oro Universal Bank, Inc. (BDO), Vivian Duldulao, and Christine Nakanishi against Liza A. Seastres and Anabelle Benaje. The petition challenges the Court of Appeals' (CA) decision affirming, with modification, the Regional Trial Court's (RTC) ruling that held BDO and its employees jointly and severally liable for unauthorized withdrawals from Seastres' bank accounts.

Seastres' Bank Accounts:
Seastres maintained personal and corporate accounts with BDO in two branches: BDO People Support Branch and BDO Rufino Branch in Makati City. In October 2008, Seastres suspected unauthorized withdrawals from her accounts and requested a transaction history.

Unauthorized Transactions:
Seastres discovered several unauthorized withdrawals and encashments of manager's checks between April and September 2008, totaling P8,121,939.59. These transactions were facilitated by Anabelle Benaje, Seastres' trusted friend and Chief Operating Officer of Las Management, a company owned by Seastres.

BDO's Investigations:
BDO conducted investigations but found no irregularities. BDO allowed Benaje to transact on Seastres' behalf based on a long-standing practice, even though the authorization documents did not permit withdrawals.

Legal Action Taken:
Seastres filed a criminal case against Benaje, which was dismissed for lack of probable cause. She then filed a civil case for collection of sum of money against BDO, Duldulao, and Nakanishi, alleging negligence in handling her accounts.

Issue:

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Ruling:

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Ratio:

  1. Banks’ Extraordinary Diligence: Banks are required to exercise the highest degree of diligence in handling depositors' accounts due to the fiduciary nature of their relationship. BDO's failure to follow its own rules and procedures constituted a breach of this duty.
  2. Contributory Negligence Not Applied: Seastres' trust in Benaje did not amount to contributory negligence. BDO's violation of its own procedures was the proximate cause of the losses.
  3. Forgery Irrelevant: The Court ruled that Seastres' failure to prove forgery of her signatures on the withdrawal slips and checks was irrelevant to BDO's liability. BDO's negligence lay in allowing the transactions despite violating its own rules.
  4. Solidary Liability: BDO, as the employer, was solely liable for the damages. Its employees, Duldulao and Nakanishi, were not held jointly and severally liable.


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