Case Digest (G.R. No. 157177) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Bank of the Philippine Islands v. Jesusa P. Reyes and Conrado B. Reyes, petitioning bank BPI and respondents Jesusa and Conrado Reyes clashed over a December 7, 1990 transaction at BPI’s Zapote Branch. Mrs. Jesusa Reyes, accompanied by her daughter Joan, sought to open an Express Teller (ATM) account and intended to deposit ₱200,000.00—₱100,000.00 to be withdrawn by fund transfer from her existing Savings Account No. 233243388 and ₱100,000.00 in cash. BPI employee Cicero Capati prepared a withdrawal slip for ₱200,000.00 which Mrs. Reyes signed; after an overdraft alert, she reduced and signed the corrected withdrawal to ₱100,000.00. Capati then prepared a deposit slip for ₱200,000.00, gave Mrs. Reyes the duplicate, and later altered the original to ₱100,000.00 before machine validation. When Mrs. Reyes learned upon updating her passbook in February 1991 that only ₱100,000.00 was credited to her new account, she sent demand letters for the missing ₱100,000.00 plus interest. Up Case Digest (G.R. No. 157177) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Nature of the Case
- Petitioner – Bank of the Philippine Islands (BPI); Respondents – Spouses Jesusa P. Reyes and Conrado B. Reyes.
- Subject – Petition for Review on Certiorari under Rule 45 aiming to annul the CA decision (Oct. 29, 2002) and its resolution (Feb. 12, 2003) that affirmed with modification an RTC decision ordering BPI to return ₱100,000 plus interest and damages.
- December 7, 1990 Transactions
- Respondent Jesusa and daughter Joan went to BPI Zapote to open an Express Teller account for ₱200,000: transfer ₱100,000 from Savings Acct. No. 233243388 and deposit ₱100,000 in cash.
- Clerk Cicero Capati prepared a withdrawal slip for ₱200,000, which Jesusa signed in good faith. Teller Torneros attempted to process the P200,000 withdrawal but the computer flagged “BIG AMOUNT,” “BALANCE ERROR,” and later “TOD (overdraft).”
- Capati and Jesusa corrected the slip—reducing it to ₱100,000 (signed by Jesusa), after which the fund transfer of ₱100,000 succeeded. A duplicate deposit slip of ₱200,000 was stamped and given to Jesusa; the original slip was later altered by Capati to reflect ₱100,000 and machine-validated.
- Procedural History
- Upon return from the U.S., Jesusa discovered only ₱100,000 credited. Two demand letters (May and Oct 1991) yielded no resolution.
- RTC (Aug 12, 1994) found BPI liable for the missing ₱100,000 with 14% interest, moral damages ₱1,000,000, exemplary damages ₱350,000, and attorney’s fees ₱250,000.
- CA (Oct 29, 2002) modified interest to 12% p.a. from May 1991, reduced moral damages to ₱50,000, deleted exemplary damages, and reduced attorney’s fees to ₱30,000. Motion for reconsideration denied Feb 12, 2003.
- SC decision (Feb 11, 2008) granted the petition, reversed CA, and dismissed respondents’ complaint and petitioner’s counterclaim.
Issues:
- Factual Issue
- Did respondent Jesusa deposit a total of ₱200,000 into her Express Teller account on December 7, 1990?
- Evidentiary and Legal Issues
- Did the CA gravely abuse its discretion by favoring testimonial evidence over physical evidence?
- Were the exceptions to the finality of CA’s findings of fact properly applied?
- What is the proper evidentiary weight of bank transaction records (teller’s tape, deposit slips) versus oral testimony?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)