Case Digest (G.R. No. 273720)
Facts:
EastWest Rural Bank v. Philippine National Police Anti‑Cybercrime Group Regional Anti‑Cybercrime Unit 1, G.R. No. 273720, July 29, 2025, First Division, Hernando, J., writing for the Court.
Petitioner EastWest Rural Bank (EWRB) seeks review of the Court of Appeals' Resolutions dated September 26, 2023 and April 30, 2024 in CA G.R. SP. No. 180524 and challenges Regional Trial Court (RTC) Orders dated July 3 and July 27, 2023 in WDCD No. 15‑2023, alleging grave abuse of discretion amounting to lack or excess of jurisdiction.
The dispute began when Leonard Vendiola reported that on May 19, 2023 he was vphished: after giving his email and one‑time password to a caller who claimed to be a bank employee, he discovered a PHP 10,000 transfer to EWRB account no. 500023412872. He lodged a complaint with PNP‑ACG RACU 1, which treated the incident as an offense under Section 9(s) of Republic Act No. 8484, as amended.
On June 13, 2023, PNP‑ACG RACU 1 applied for a warrant to disclose computer data (WDCD) under the Cybercrime Prevention Act (RA No. 10175). The RTC issued the WDCD on June 21, 2023, authorizing disclosure and preservation of specified data related to the EWRB account—namely the account holder’s full name, personal information, verification ID, contact details, and “any other relevant information” to identify the account holder and digital footprint. PNP‑ACG RACU 1 thereafter issued a Disclosure Order to EWRB.
EWRB filed an Entry of Appearance and a Motion for Clarificatory Order with the RTC, arguing that (1) the requested information was unrelated to any pending court case; (2) the Bank Secrecy Law (RA No. 1405) remained in force and barred such disclosure; and (3) EWRB was not a “service provider” under the Cybercrime Prevention Act or its Rules, and thus not obliged to comply. The RTC denied EWRB’s motion on July 3, 2023 and denied reconsideration on July 27, 2023, explaining the WDCD sought identity information rather than deposit amounts and suggesting challenges could be raised in the criminal case that might later be filed.
EWRB petitioned the Court of Appeals for certiorari with application for TRO; the CA dismissed the petition on September 26, 2023 for procedural deficiencies (omitted petitioner address, an illegible Annex D, and absent MCLE details for the notary) and found no grave abuse of discretion by the RTC. A motion for reconsideration was denied April 30, 2024. EWRB then filed this Petition for Review on Certiorari under Rule 45.
The Office of the Solicitor General (OSG) filed a manifestation arguing the WDCD contravened the Bank Secrecy Law and that EWRB was...(Pro-only)
Issues:
- Did the procedural deficiencies noted by the Court of Appeals justify dismissal of EWRB’s petition, or should the petition proceed on the merits?
- Did the Cybercrime Prevention Act (RA No. 10175) implicitly repeal or supersede the confidentiality provisions of the Bank Secrecy Law (RA No. 1405) concerning bank deposits?
- Does EWRB qualify as a “service provider” under the Cybercrime Prevention Act and therefore fall within the Act’s disclosure and cooperation obligations?
- Did the WDCD issued by the RTC unlawfully violate bank secrecy by compelling disclosure of deposit‑related information, or was it limited to...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)