Case Digest (G.R. No. 66826) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Bank of the Philippine Islands v. Intermediate Appellate Court and Rizaldy T. Zshornack (G.R. No. 66826, August 19, 1988), the original dispute arose between Rizaldy T. Zshornack and the Commercial Bank and Trust Company of the Philippines (“COMTRUST”) after Zshornack filed a complaint on June 28, 1976 in the Court of First Instance of Rizal–Caloocan City, alleging four causes of action involving unauthorized withdrawals and failure to return entrusted funds. In 1980, COMTRUST merged with the Bank of the Philippine Islands (“BPI”), which was substituted as defendant. The trial court ruled in Zshornack’s favor on all but the third cause; on appeal, the Intermediate Appellate Court (“IAC”) modified the decision by absolving the bank of liability on the fourth cause and ordering COMTRUST to (1) restore US$1,000.00 to Zshornack’s dollar savings account with interest, (2) return US$3,000.00 held for safekeeping, and (3) pay ₱8,000.00 as litigation expenses and attorney’s fees. BPI Case Digest (G.R. No. 66826) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural History
- Rizaldy T. Zshornack filed a complaint on June 28, 1976 in the CFI of Rizal–Caloocan City against Commercial Bank and Trust Company of the Philippines (COMTRUST), alleging four causes of action.
- In 1980, Bank of the Philippine Islands (BPI) absorbed COMTRUST by corporate merger and was substituted as party.
- Account Relationships and Transactions
- Zshornack maintained with COMTRUST, Quezon City Branch:
- Dollar Savings Account No. 25-4109
- Peso Current Account No. 210-465-29
- First Cause of Action – Unauthorized Withdrawal:
- On October 27, 1975, Assistant Branch Manager Virgilio V. Garcia processed an application for a US$1,000 dollar draft payable to Leovigilda D. Dizon, charged to Dollar Savings Account No. 25-4109; associated fees were charged to the Peso Current Account.
- COMTRUST issued the draft drawn on Chase Manhattan Bank, New York, without naming the purchaser.
- Upon discovery of the withdrawal, the bank claimed the peso equivalent had been paid to Zshornack’s brother, Ernesto, or that an agreement authorized the withdrawal to fund the peso account.
- Second Cause of Action – Safekeeping Deposit:
- On December 8, 1975, Zshornack delivered US$3,000 in cash to COMTRUST for safekeeping, acknowledged by Garcia in a signed receipt.
- Upon demand for return on May 10, 1976, the bank sold US$2,000 on December 29, 1975 (P14,920) and US$1,000 on February 3, 1976 (P8,350), crediting proceeds to Zshornack’s peso account.
- Decisions Below
- The CFI ruled in favor of Zshornack on all causes of action except the third.
- The IAC modified the CFI decision by absolving COMTRUST on the fourth cause and ordering:
- Restoration of US$1,000 to the dollar savings account with interest per Central Bank Circular 343;
- Return of US$3,000 (without interest);
- Payment of P8,000 as litigation expenses and attorney’s fees.
- BPI appealed, limiting issues to liability on the first and second causes and the award of damages.
Issues:
- Is BPI liable for the unauthorized withdrawal of US$1,000 in the first cause of action?
- Is Zshornack entitled to recover US$3,000 under the second cause of action for safekeeping?
- Is the award of P8,000 for litigation expenses and attorney’s fees proper and reasonable?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)