Case Digest (G.R. No. 199562) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Bank of the Philippine Islands and Ana C. Gonzales v. Spouses Fernando V. Quiaoit and Nora L. Quiaoit (G.R. No. 199562, January 16, 2019), Fernando V. Quiaoit maintained peso and dollar accounts with BPI’s Greenhills-Crossroads Branch. On April 20, 1999, through his authorized representative Merlyn Lambayong, he encashed Check No. 003434 for US$20,000. The bank marked the bills with a branch “chapa” but did not list their serial numbers nor inform Lambayong of the marking. Lambayong delivered the two bundles of US$100 bills to the Quiaoits, who left for travel abroad on April 22, 1999. While in Madrid, Nora experienced public embarrassment when several banks and merchants refused to accept some of the bills as they were counterfeit. Friends and relatives confirmed the bills’ rejection and returned five suspect notes via courier. On May 21, 1999, the spouses’ daughter, an employee of BPI Makati, relayed the incident to Branch Manager Ana C. Gonzales, who failed to address the Case Digest (G.R. No. 199562) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and initial withdrawal
- Fernando V. Quiaoit maintained peso and dollar accounts with Bank of the Philippine Islands (BPI) Greenhills–Crossroads Branch.
- On April 20, 1999, through his representative Merlyn Lambayong, Fernando encashed BPI Check No. 003434 dated April 19, 1999 for US$20,000 in US$100 bills; the bills were handed over in a Manila envelope and bundles without listing their serial numbers.
- Discovery of counterfeit bills and bank’s handling
- During a trip to Jerusalem and Europe, Nora Quiaoit experienced refusal of several US$100 bills as counterfeit by foreign banks and merchants; friends and relatives also returned bills as unexchangeable.
- While still abroad, the spouses’ daughter informed BPI Greenhills of the predicament; branch manager Ana C. Gonzales failed to respond. Upon return, the spouses personally complained; they surrendered the remaining 44 US$100 bills (US$4,400) to Gonzales, who acknowledged receipt but did not list serial numbers.
- BPI conducted an internal investigation, ultimately concluding the 44 bills were from another source because they lacked the branch’s identifying “chapa.”
- Demand, trial, and appellate proceedings
- On January 17, 2000, the spouses formally demanded refund of US$4,400; BPI refused on February 9, 2000, alleging compliance with banking procedures.
- The spouses sued for actual, moral, exemplary damages, and attorney’s fees. The Regional Trial Court (May 15, 2009) and the Court of Appeals (September 22, 2011; November 29, 2011 resolution) ruled in favor of the spouses, finding BPI negligent and the proximate cause of their loss.
Issues:
- Source of counterfeit bills
- Whether the counterfeit US$100 bills surrendered by the spouses originated from BPI Greenhills.
- Exercise of diligence
- Whether BPI exercised the highest degree of diligence in handling the withdrawal of foreign currency and in listing serial numbers.
- Liability for damages
- Whether BPI is liable for actual, moral, exemplary damages, and attorney’s fees due to its alleged negligence or bad faith.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)