Case Digest (A.M. No. P-208)
Facts:
The case involves two consolidated petitions for review on certiorari, G.R. No. 148196 and G.R. No. 148259, with BPI Family Bank (BPI-FB) as the petitioner in the first case and Edgardo Buenaventura, Myrna Lizardo, and Yolanda Tica (collectively referred to as Buenaventura, et al.) as the respondents. The events leading to the case began on May 23, 1990, when Buenaventura, et al., who were officers of the International Baptist Church and International Baptist Academy in Malabon, Metro Manila, filed a complaint against BPI-FB for "Reinstatement of Current Account/Release of Money plus Damages" before the Regional Trial Court (RTC) of Manila, which was docketed as Civil Case No. 90-53154. The complaint stemmed from a series of transactions involving BPI-FB Check No. 129004, dated August 29, 1989, for the amount of P500,000.00, which was deposited into their Current Account No. 807-065314-0 after being cleared.
On September 3, 1989, they issued a check for P10,171.5...
Case Digest (A.M. No. P-208)
Facts:
Opening of the Current Account
On August 30, 1989, Edgardo Buenaventura, Myrna Lizardo, and Yolanda Tica (respondents), officers of the International Baptist Church and International Baptist Academy, accepted a BPI-FB Check No. 129004 dated August 29, 1989, in the amount of P500,000.00 from Amado Franco. The check was jointly issued by Eladio Teves and Joseph Teves. They opened Current Account No. 807-065314-0 with BPI Family Bank (BPI-FB) and deposited the check as the initial deposit. The check was cleared, and the amount was credited to their account.
Withdrawals and Freezing of the Account
On September 3, 1989, the respondents drew a check for P10,171.50, which was honored, leaving a balance of P490,328.50. On September 4, 1989, they drew another check for P46,189.60, but instead of debiting it from their Current Account, BPI-FB debited it from their Savings Account without their knowledge or consent. On September 9, 1989, they drew a check for P91,270.00, which was dishonored with the reason "account closed," despite the balance in the Current Account. They later learned that BPI-FB had frozen their Current Account upon the instruction of Severino P. Coronacion, Vice-President of BPI-FB, on the ground that the source of the funds was illegal or unauthorized.
Legal Proceedings
The respondents filed a complaint for "Reinstatement of Current Account/Release of Money plus Damages" against BPI-FB before the Regional Trial Court (RTC) of Manila. BPI-FB filed a motion to dismiss on the ground of litis pendentia, citing a pending case for recovery of sum of money involving the same check. The RTC denied the motion, ruling that there was no identity of parties or causes of action between the two cases.
BPI-FB, in its answer, alleged that the check received by the respondents was drawn against the account of Tevesteco Arrastre Stevedoring Co., Inc. (Tevesteco), which had received funds from the First Metro Investment Corporation (FMIC) based on a forged Authority to Debit. BPI-FB claimed the right to freeze the respondents' account to protect its interests.
Issue:
- Whether the respondents are the real parties-in-interest in the case.
- Whether BPI-FB had the right to unilaterally freeze the respondents' Current Account.
- Whether the funds in the respondents' account were derived exclusively from the alleged P80,000,000.00 unlawfully transferred from FMIC's account.
- Whether the Court of Appeals erred in affirming the RTC's decision to order BPI-FB to pay the balance of the account plus interest, despite the respondents' prayer only for reinstatement of the account.
- Whether the award of exemplary damages was proper.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court denied BPI-FB's petition and granted the respondents' petition, affirming the CA's decision with the modification that BPI-FB is directed to pay P50,000.00 as exemplary damages. The Court emphasized the fiduciary nature of the bank-depositor relationship and the need for banks to exercise the highest degree of diligence in handling depositors' accounts.