Title
Bank of America NT&SA vs. Court of Appeals
Case
G.R. No. 120135
Decision Date
Mar 31, 2003
Litonjuas sued banks for breach of trust over vessel revenues, alleging mismanagement. Philippine courts upheld jurisdiction, allowing case to proceed.

Case Digest (G.R. No. 120135)
Expanded Legal Reasoning Model

Facts:

  • Parties and Background
    • Eduardo K. Litonjua, Sr. and Aurelio K. Litonjua, Jr. (the Litonjuas) engaged in shipping, owning two vessels (Don Aurelio, El Champion) through wholly-owned corporations.
    • Revenues and other funds were deposited with Bank of America NT&SA and Bank of America International, Ltd. (the defendant banks) in branches abroad.
  • Loan and Security Arrangements
    • Banks induced the Litonjuas to acquire four additional vessels (El Carrier, El General, El Challenger, El Conqueror) by extending loans to their corporations.
    • Legal title, operation, and disposition of funds were placed under exclusive control of the banks or their designated agents.
  • Alleged Breach and Foreclosure
    • The Litonjuas claimed the banks, as trustees, failed to render an accounting of vessel revenues and foreclosure-sale proceeds.
    • Due to alleged negligence and breach of fiduciary duty, vessel revenues declined, loans matured unpaid, vessels were foreclosed and sold, causing the Litonjuas substantial losses.
  • Procedural History
    • The Litonjuas filed suit in the RTC of Pasig for accounting, damages for breach of trust, exemplary damages, and attorney’s fees.
    • Defendant banks moved to dismiss on grounds of lack of personality to sue, failure to state a cause of action, forum non conveniens, and res judicata/litis pendentia.
    • The RTC denied the motion; banks elevated the order via certiorari to the Court of Appeals, which dismissed the petition and denied reconsideration.
    • Banks filed a Rule 45 petition for certiorari with the Supreme Court.

Issues:

  • Whether the RTC gravely abused its discretion in denying dismissal for lack of personality to sue or cause of action.
  • Whether the complaint should have been dismissed on the doctrine of forum non conveniens.
  • Whether the pendency of foreign suits constituted litis pendentia/forum shopping warranting dismissal.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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