Case Digest (G.R. No. 256144)
Facts:
This is Equitable PCIBank v. Spouses Maximo and Soledad Lacson and Marietta F. Yuching, G.R. No. 256144, March 06, 2023, First Division, Rosario, J., writing for the Court. The petition arose from a suit filed by Equitable PCIBank (EPCIB) against Spouses Maximo and Soledad Lacson (the Lacsons) and Marietta F. Yuching (Yuching), then Branch Manager of EPCIB’s C.M. Recto branch, for sums allegedly lost to a check‑kiting scheme and for damages.From November 2002 to January 2003 the Lacsons maintained two current accounts at EPCIB (one joint account of the spouses and one in the name of their daughter). EPCIB alleged that the Lacsons, in connivance with Yuching, engaged in check kiting—issuing checks against insufficient funds and using “on us” or same‑branch checks to temporarily inflate account balances; EPCIB’s investigation identified 214 checks later found Drawn Against Insufficient Funds (DAIF), and two P10,000,000 checks were dishonored for being drawn on a closed account. On January 7, 2003 EPCIB froze activities on the accounts and later sought settlement by REMs that were not executed.
EPCIB filed a Complaint for Sum of Money and Damages with Prayer for Preliminary Attachment on June 4, 2003 (RTC, Makati City, Civil Case No. 03‑618). Yuching denied conspiracy and alleged she discovered the scheme only in December 2002 and participated in settlement efforts; the Lacsons denied fraudulent conduct and challenged the bank’s debits and handling. The RTC (Branch 58) on June 11, 2018 rendered judgment in favor of EPCIB ordering the Lacsons to pay P20,000,000 actual damages, and holding the Lacsons and Yuching solidarily liable for P500,000 exemplary damages, P300,000 attorney’s fees, and costs; the RTC denied reconsideration on January 22, 2019.
The Lacsons appealed to the Court of Appeals (CA). On January 25, 2021 the CA (CA‑G.R. CV No. 114270) reversed and set aside the RTC decision, entered a new judgment dismissing EPCIB’s complaint, and lifted the writ of attachment on the Lacsons’ properties; the CA denied EPCIB’s motion for reconsideration by Resolution dated March 10, 2021. EPCIB then b...(Pro-only)
Issues:
- Did EPCIB prove actual (compensatory) damages in the amount of P20,000,000 by a preponderance of evidence?
- If not, was EPCIB nevertheless entitled to exemplary damages, attorney’s fees, and costs of suit?
- Did the Court of Appeals commit reversible error in reversing the RTC and dismis...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
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