Case Digest (G.R. No. 159611)
Facts:
In Citibank, N.A. (formerly First National City Bank) and Investors’ Finance Corporation (doing business as FNCB Finance) v. Modesta R. Sabeniano, decided October 16, 2006 under G.R. No. 156132, the respondent Sabeniano, a long‐time client, maintained peso and dollar deposits and money‐market placements with petitioners. Beginning in December 1976 she rolled over several peso placements with Citibank (PN No. 20773, later superseded by PNs 23356 and 23357), and in April 1977 she pre-terminated time deposits totaling P1.1 million to invest with FNCB Finance (PNs 4952, 4962, later superseded by PNs 5757, 5758, then by PNs 8167, 8169, and finally by PNs 20138, 20139). In early 1978 and 1979 Sabeniano obtained peso loans totaling P1.92 million from Citibank, evidenced by promissory notes secured by deeds of assignment of her FNCB money-market placements and by a Declaration of Pledge over her Citibank‐Geneva dollar accounts. When she failed to pay, Citibank credited against her loanCase Digest (G.R. No. 159611)
Facts:
- Parties and relationships
- Petitioners: Citibank, N.A. (formerly First National City Bank) and FNCB Finance (affiliate, now BPI Card Finance).
- Respondent: Modesta R. Sabeniano, client holding peso placements with Citibank and FNCB Finance, and dollar accounts with Citibank‐Geneva.
- Transactions and securities
- 1976–77: Sabeniano’s peso money‐market placements with Citibank (PNs 20773→21686→22526/22528→23356/23357); alleged but unproven payment of PNs 23356/23357.
- 1977–78: Pre‐termination of Citibank time deposits → Manager’s Checks (MCs 199253/199251) → placements with FNCB Finance (PNs 4952/4962→5757/5758→8167/8169→20138/20139).
- 1978–79: Sabeniano obtained Citibank loans (total ₱1.92 M) evidenced by “first set” PNs (e.g. 32935, 33751…) and renewed in “second set” PNs (34510–35697), secured by Deeds of Assignment of PNs 8167/8169 and later PNs 20138/20139; executed a Declaration of Pledge over “all present and future fiduciary placements” in Citibank‐Geneva.
- Setoffs, disputes, and early rulings
- Apr–Oct 1979: Letters between Sabeniano and Citibank on past‐due loans; Citibank set off ₱31,079.14 (savings), ₱1,022,916.66 (FNCB proceeds) and US $149,632.99 (Geneva remittance) against her loan balance.
- Civil Case No. 11336 (RTC Makati, Aug 1985): Trial, Decision Aug 24 1995 declared Geneva setoff illegal, affirmed debt ₱1,069,847.40, dismissed other claims.
- CA-G.R. CV No. 51930 (Mar 26 2002): Modified RTC, ordered return of placements/accounts (including Geneva funds), awarded ₱500k moral and exemplary damages and ₱100k attorney’s fees.
- CA Res. Nov 20 2002: Deleted return of AIDC placement.
- SC G.R. No. 152985: Sabeniano’s appeal terminated for failure to file petition.
- SC G.R. No. 156132: Citibank/FNCB petition reinstated for SC review under Rule 45.
Issues:
- Procedural
- Did Sabeniano commit forum shopping or fail certification?
- May SC review CA’s factual findings under Rule 45 exceptions?
- Existence/payment of instruments
- Were Citibank PNs 23356/23357 paid and invested in time deposits?
- Were FNCB PNs 5757/5758/20138/20139 paid with proceeds returned?
- Did Sabeniano owe ₱1.92 M loans (PNs “first”/“second” sets)?
- Authority for setoff
- Validity of Deeds of Assignment (FNCB placements) and Declaration of Pledge (Geneva deposits).
- Was setoff of savings and FNCB proceeds valid under Art. 1278 CC?
- Was remittance of Geneva accounts valid without proper pledge?
- Evidentiary
- Applicability of best-evidence rule to PNs, MCs, deeds.
- Weight of signatures and forgery claims.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)