Case Digest (G.R. No. 211519) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 211519, decided on August 14, 2017 under the 1987 Constitution, the late Rodolfo Dela Cruz, proprietor of Mamertha General Merchandising in Caloocan City, maintained Savings Account No. 002-004-00008-1 with Panasia Banking, Inc. in October 1998. He discovered that his son, Allan Dela Cruz, had withdrawn without authority some ₱56,223,066.07, despite a written instruction dated October 5, 1998, delivered to Panasia’s Grace Park branch manager on October 16, 1998, directing that no withdrawals be allowed. Panasia nevertheless honored the unauthorized checks. When Dela Cruz demanded restoration and re-deposit of the funds, the bank refused, prompting him on August 7, 2000 to file a collection suit (RTC Caloocan, Civil Case No. C-19332), later amended to add Bank of Commerce as a co-defendant. Dela Cruz secured a temporary restraining order and, eventually, a writ of preliminary injunction against foreclosure of his mortgaged properties. Panasia was declared in default, Case Digest (G.R. No. 211519) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Antecedents
- Rodolfo Dela Cruz filed a complaint for collection of money and damages against Panasia Banking, Inc. (Panasia) before the RTC of Caloocan City, later amending to include Bank of Commerce as additional defendant.
- A temporary restraining order and preliminary injunction were issued against Panasia, Bank of Commerce, and certain court officers to stop an extra-judicial auction of mortgaged properties.
- Dela Cruz died in 2003 and was substituted by his heirs through his spouse and children.
- Facts Underlying the Dispute
- Dela Cruz, sole proprietor of Mamertha General Merchandising, maintained a savings account with Panasia. In October 1998 he discovered unauthorized withdrawals by his son, Allan, and sent written instructions forbidding further withdrawals without his express consent.
- Despite these instructions, withdrawals totaling ₱56,223,066.07 were made. Dela Cruz demanded restoration of the funds and later filed suit for collection on August 7, 2000.
- In September 2000, Bank of Commerce—having acquired selected assets and liabilities of Panasia under a Purchase and Sale Agreement dated July 27, 2000 and a Deed of Assignment dated September 18, 2000—demanded payment from Dela Cruz of ₱27,150,000 as unpaid loans.
- Trial Court Proceedings
- The RTC found Panasia negligent for allowing unauthorized withdrawals and held both Panasia and Bank of Commerce jointly and severally liable for ₱56,223,066.00, less ₱27,150,000 set-off, plus attorney’s fees and costs.
- On appeal, the CA affirmed, ruling that Bank of Commerce failed to formally offer the Purchase and Sale Agreement and Deed of Assignment, thus cannot prove it did not assume Panasia’s liabilities.
Issues:
- Whether the petitioner’s failure to formally offer the Purchase and Sale Agreement and Deed of Assignment was fatal to its defense.
- Whether Bank of Commerce can be held solidarily liable for the negligence of Panasia.
- Whether there was any admission by Dela Cruz that he authorized his son’s withdrawals, thus negating Panasia’s negligence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)