G.R. No. 239092 - Bank of the Philippine Islands vs. Spouses Sarda

Petitioner: Bank of the Philippine Islands (BPI), a domestic commercial banking corporation engaged in issuing credit cards.
Respondents: Spouses Ram M. Sarda and “Jane Doe” Sarda, who are alleged to have incurred an outstanding obligation through the use of the credit card(s) in question.

BPI issued a credit card to Mr. Sarda under standard terms and conditions to its pre-qualified clients.
A supplementary card was issued in the name of Ms. Tandogon, who is purported to have been an employee rather than a family member, without Mr. Sarda’s explicit application or prior consent.
BPI’s records, including statements of account, indicated that significant transactions (purchases and cash advances) were made under both the primary and supplementary cards, accumulating an obligation of approximately P1,213,114.19.

The Regional Trial Court (RTC) of Makati City, Branch 143, rendered a decision ordering respondents to pay the principal amount plus finance charges, late payment fees, and attorney’s fees.
BPI presented various documentary evidence (delivery receipt, Terms and Conditions, billing statements) and testimony from its Account Specialist, Mr. Arlito M. Igos.
Respondents contended that they neither applied for nor received the credit cards, denied using them, and argued that they never received the monthly billing statements or demand letters at their proper address.
The Court of Appeals (CA) reversed the RTC decision on the basis that BPI failed to prove that Mr. Sarda had actual possession or consented to the card issuance and subsequent transactions.

BPI relied on the delivery receipt (signed by Ms. Tandogon), a series of statements of account, and internal records showing transactions at various reputable establishments.
A discrepancy emerged regarding the billing address, with a notation on the demand letter casting doubt on whether respondents had actually received the statements.
Respondents maintained that the absence of a signed application and explicit consent invalidated the presumed contractual obligation for the accrued amounts.

Whether Mr. Sarda (and by extension, the respondents) should be held liable for the outstanding obligation arising from the use of the credit card(s) issued by BPI.

Whether the documentary evidence presented by BPI was sufficient to establish, by a preponderance of evidence, that the respondents incurred the alleged obligations.

Does the mere appearance of continuous billing and payment records conclusively prove the use of the cards by the cardholder?
Is the delivery receipt signed by a third party (Ms. Tandogon) enough to establish acceptance by the intended cardholder?

Whether BPI exercised the necessary due diligence and complied with regulatory requirements in issuing both the principal and supplementary credit cards.

Did BPI follow proper procedures (including obtaining clear and explicit consent) as required under prevailing credit card regulations and law?
Was the issuance of an unsolicited supplementary card in contravention of established banking practices and regulatory circulars?