Case Digest (G.R. No. 116792)
Facts:
Bank of the Philippine Islands and Grace Romero, petitioners, v. Court of Appeals and Edvin F. Reyes, respondents, G.R. No. 116792, March 29, 1996, the Supreme Court En Banc, Puno, J., writing for the Court. Petitioners sought review of the Court of Appeals Decision in CA-G.R. CV No. 41543 (Sixteenth Division) which had reversed the Regional Trial Court of Quezon City, Branch 79 (Civil Case No. Q-91-8451, Presiding Judge Godofredo L. Legazpi) and ordered petitioners to credit respondent Reyes’ Savings Account No. 3185-0172-56 with P10,556.00 plus interest.On September 25, 1985, Edvin F. Reyes opened Savings Account No. 3185-0172-56 at the BPI Cubao Shopping Center Branch, a joint "AND/OR" account with his wife Sonia S. Reyes. On February 11, 1986 he also opened with the same branch a joint "AND/OR" Savings Account No. 3185-0128-82 with his grandmother, Emeteria M. Fernandez, into which he regularly deposited U.S. Treasury Warrants payable to Fernandez as her monthly pension. Fernandez died on December 28, 1989, unknown to the U.S. Treasury Department, which nevertheless issued U.S. Treasury Warrant No. 21667302 dated January 1, 1990 for U.S. $377.00 (P10,556.00). On January 4, 1990, Reyes deposited that warrant into Savings Account No. 3185-0128-82. The check was conditionally cleared by the U.S. Veterans Administration Office in Manila and sent to the United States for final clearing.
On March 8, 1990 Reyes closed Savings Account No. 3185-0128-82 and transferred its balance (P13,112.91) to his joint account with his wife (No. 3185-0172-56). On January 16, 1991 the U.S. Treasury Warrant was dishonored when it was discovered that Fernandez had died prior to its issuance; the U.S. Department of Treasury requested a refund from BPI. On February 19, 1991 BPI sent Reyes a telegram asking him to contact Branch Manager Grace S. Romero or Asst. Manager Carmen Bernardo. According to bank witnesses, Reyes called, was informed of the dishonor and of a refund claim by Citibank N.A., and verbally told the bank "don't you worry about it" and promised written authorization, thereby authorizing the bank to debit his other joint account. That same day BPI debited P10,556.00 from Savings Account No. 3185-0172-56.
Reyes later visited the bank (February 21, 1991), demanded restitution and then filed suit for damages (Civil Case No. Q-91-8451), alleging wrongful debit. Petitioners answered, counterclaimed for damages, and asserted as a special affirmative defense that Reyes had given express verbal authority and that legal compensation entitled the bank to apply the deposit to its claim arising from the returned warrant. The RTC dismissed Reyes’ complaint for lack of cause of action in a Decision dated January 20, 1993. ...(Pro-only)
Issues:
- Did Edvin F. Reyes give express verbal authority to BPI to debit his joint "AND/OR" Savings Account No. 3185-0172-56 for the amount of the returned U.S. Treasury Warrant?
- Could BPI legally apply the doctrine of legal compensation to debit Reyes’ joint account for the bank’s claim arising from the dishonored U.S. Treasury Warrant, despite the p...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)