Title
Bank of the Philippine Islands vs. Intermediate Appellate Court
Case
G.R. No. 74678
Decision Date
Mar 8, 1993
BPI negligently delayed clearing Romax's deposited check, causing dishonor of its issued check, damaging business reputation. SC affirmed negligence but deleted unproven damages.
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Case Digest (G.R. No. 74678)

Facts:

  1. Account and Deposit Details

    • Private respondent Romax Marketing Center, Inc., a domestic corporation engaged in trading construction materials, maintained a current account with petitioner Bank of the Philippine Islands (BPI), formerly Commercial Bank and Trust Company (CBTC), under Current Account No. 115-178-12.
    • On November 28, 1975, between 10:00 a.m. and 10:30 a.m., Romax deposited a check worth P25,000.00 into its account. The deposit slip was stamped "3 DAYS TO CLEAR."
    • Romax's bank balance on November 28, 1975, was approximately P3,000.00.
  2. Issuance and Dishonor of Check

    • On November 29, 1975, Romax issued CBTC Check No. 85063 for P27,475.90 payable to Far Eastern Plumbing Supply, Inc. for materials purchased.
    • On December 3, 1975, BPI dishonored the check, citing "Drawn Against Uncollected Deposit."
    • Far Eastern Plumbing Supply, Inc. refused to redeposit the check, expressing loss of confidence in Romax's checks.
    • On December 4, 1975, BPI issued a cashier's check to Far Eastern Plumbing Supply, Inc. for the full amount of the dishonored check.
  3. Impact on Romax's Business

    • The dishonor of the check severely damaged Romax's business reputation and credit standing, making it difficult to secure credit facilities.
    • Romax claimed it could not meet purchase orders from clients due to the loss of trust and credit.
  4. Legal Action

    • On December 8, 1975, Romax demanded P700,000.00 in damages from BPI for negligence in dishonoring the check.
    • On February 6, 1976, Romax filed a complaint for damages against BPI in the Court of First Instance of Pasig.
    • BPI defended itself by stating that the check was deposited after the 2:00 p.m. clearing cut-off time on November 28, 1975, and was only sent for clearing on December 1, 1975.
    • BPI also claimed that Romax's account had a negative balance when the check was presented for payment.
  5. Trial Court Decision

    • The trial court ruled in favor of Romax, awarding:
      • P150,000.00 as compensatory damages for injury to business standing.
      • P50,000.00 as damages for loss of income.
      • P10,000.00 as attorney's fees.
      • Costs of suit.
  6. Appeal to Intermediate Appellate Court

    • BPI appealed to the Intermediate Appellate Court, which affirmed the trial court's decision on April 2, 1986.
    • The appellate court found BPI negligent for failing to send the deposited check for clearing on time, which caused Romax's check to be dishonored.

Issue:

  1. Whether BPI was negligent in failing to send Romax's deposited check for clearing on time, resulting in the dishonor of Romax's issued check.
  2. Whether the trial court and appellate court correctly awarded compensatory damages and damages for loss of income to Romax.
  3. Whether Romax sufficiently proved the actual damages it claimed.

Ruling:

The Supreme Court affirmed the decision of the Intermediate Appellate Court but modified the award of damages. The Court held:

  1. Negligence of BPI

    • BPI was negligent in failing to send Romax's deposited check for clearing on November 28, 1975, despite evidence that the check was deposited before the 2:00 p.m. cut-off time.
    • This negligence directly caused the dishonor of Romax's check, damaging its business reputation and credit standing.
  2. Award of Damages

    • The Court upheld the award of attorney's fees and costs of suit.
    • However, the Court deleted the awards of P150,000.00 as compensatory damages and P50,000.00 as damages for loss of income, as Romax failed to prove these damages with reasonable certainty.
    • The Court emphasized that actual or compensatory damages must be proven and cannot be based on speculation or conjecture.

Ratio:

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