Facts:

The case at hand involves a petition for review filed by the Bank of the Philippine Islands (BPI) against respondents Amado M. Mendoza and Maria Marcos vda. de Mendoza. This legal battle initiated with a Complaint for Sum of Money with Application for Writ of Attachment filed by BPI against the Mendoza respondents before the Regional Trial Court (RTC) of Gapan City, Nueva Ecija, Branch 87, on January 20, 1998, under Civil Case No. 1913. The case stemmed from a series of transactions that began on April 8, 1997, when Amado and Maria opened a foreign currency savings account at BPI’s Gapan Branch. They deposited a total of $16,264.00, which comprised $100.00 in cash and $16,164.00 from a US Treasury Check, later referred to as the subject check. They also placed $2,000.00 in a time deposit account. Following the expiration of the thirty-day clearing period, they withdrew $16,244.00 from the US savings account on May 9 and 13, 1997, leaving only $20.00 to cover bank charges.

Howeve

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Facts:

Background of the Case

• BPI filed a Complaint for Sum of Money with Application for Writ of Attachment against respondents Amado M. Mendoza and Maria Marcos Vda. de Mendoza at the RTC of Gapan City, Nueva Ecija.
• The complaint stemmed from transactions involving a foreign currency savings account and a time deposit account opened by the respondents at BPI-Gapan Branch.

Transaction Details and Alleged Dishonor

• On April 8, 1997, respondents:
• Opened a US savings account (Account No. 0584-0007-08) and deposited a total amount of US$16,264.00, consisting of US$100.00 in cash and US$16,164.00 represented by a US Treasury Check (subject check) payable to “Ma. Marcos Vda. de Mendoza.”
• Placed US$2,000.00 in a time deposit account.
• After the standard thirty-day clearing period (May 9 and 13, 1997), respondents withdrew US$16,244.00 from their US savings account, leaving only US$20.00 to cover bank charges.
• On June 26, 1997, BPI received notification from its correspondent bank, Bankers Trust Company New York, that the subject check was dishonored due to an “amount altered.”
• Evidence included an electronic mail (e-mail) advice and a photocopy of the subject check stamped “ENDORSEMENT CANCELLED” by Bankers Trust.
• It was alleged that the original check had been confiscated by the US government.

BPI’s Actions Following the Notice

• BPI informed the respondents of the dishonor and demanded reimbursement of the proceeds withdrawn from the savings account.
• BPI alleged:
• On July 18, 1997, respondents permitted the bank to apply the proceeds of the time deposit account (US$2,015.00) to their outstanding obligation.
• Amado executed a promissory note dated September 8, 1997, promising to pay BPI an installment of P1,000.00 monthly.
• After multiple demands, BPI sent a final demand letter to respondents on November 27, 1997.

Respondents’ Position

• Respondents admitted the withdrawals from the account and their subsequent exchange with BPI at the prevailing rate but contended that they had not received the full amount credited by the bank (P582,140.00).
• Amado claimed that his signature on the letter dated July 18, 1997, was merely an acknowledgment of receipt rather than consent to the application of the time deposit proceeds.
• Moreover, Amado argued that he would have settled the obligation if BPI had presented authenticated proof of the dishonor of the subject check.

Procedural History

• The RTC, in its Decision dated May 9, 2007, ruled in favor of BPI ordering the respondents to pay a computed amount of P369,600.51, inclusive of legal interest at 12% per annum, and additional attorney’s fees.
• The Regional Trial Court based its ruling on:
• BPI’s proper notification to respondents regarding the dishonor.
• Amado’s voluntary acknowledgment and subsequent conduct, including execution of the promissory note.
• The principle of solutio indebiti under Article 2154 of the Civil Code.
• On appeal, the Court of Appeals (CA), in a Decision dated February 4, 2011, reversed and set aside the RTC ruling.
• The CA held that BPI failed to prove the dishonor of the subject check because:
• The photocopy violated the Best Evidence Rule.

ii. The e-mail advice was not properly authenticated per the Rules on Electronic Evidence.

Issue:

• Whether the Court of Appeals erred in dismissing BPI’s complaint for lack of merit based on its finding that the evidence presented failed to prove the dishonor of the subject check.
• Whether the presentation of secondary evidence (a photocopy of the subject check and the e-mail advice) should be deemed admissible under the exception to the Best Evidence Rule.
• Whether the RTC’s findings, particularly in light of Amado’s voluntary acts (signing the acknowledgement letters and executing the promissory note), are supported by a preponderance of the evidence that establishes the respondents’ obligation.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)