Case Digest (G.R. No. 202514)
Facts:
On August 12, 2004, Anna Marie L. Gumabon filed a complaint for recovery of sum of money and damages against the Philippine National Bank (PNB) and its Delta branch manager, Silverio Fernandez, after the bank refused to release her consolidated savings account balance and funds in two foreign exchange time deposits evidenced by Foreign Exchange Certificates of Time Deposit (FXCTD) Nos. A-993902 and A-993992. In 2001, Anna Marie and her family deposited USD 10,945.28 and USD 16,830.91, respectively, in those FXCTDs and held eight savings accounts with PNB. Seeking to assist her sister, she instructed PNB to consolidate her savings and withdrew ₱2,727,235.85 in April 2003, only to be told withdrawals were blocked due to missing records and the absence of the bank employee handling her files. After demand letters, PNB executed a Deed of Waiver and Quitclaim on May 23, 2003, acknowledging total deposits of ₱2,734,207.36 and a remaining balance of ₱250,741.82 in Savings Account No. 6Case Digest (G.R. No. 202514)
Facts:
- Initial Deposits and Account Holdings
- In 2001, Anna Marie L. Gumabon, together with her mother Angeles and siblings Anna Elena and Santiago, deposited USD 10,945.28 and USD 16,830.91 with Philippine National Bank (PNB) Delta Branch, evidenced by Foreign Exchange Certificates of Time Deposit (FXCTD) Nos. A-993902 and A-993992.
- The Gumabons also maintained eight (8) peso savings accounts with the same branch.
- Account Consolidation and Withdrawal Attempts
- April 2003: Anna Marie sought to consolidate her eight savings accounts and withdraw ₱2,727,235.85. On April 14–15, PNB refused to process the consolidation and withdrawal due to missing records and the unavailability of the assigned account officer, Reino Antonio Salvoro.
- May 23, 2003: Anna Marie, her mother, and PNB executed a Deed of Waiver and Quitclaim acknowledging a consolidated savings deposit of ₱2,734,207.36. After subsequent withdrawals, the balance stood at ₱250,741.82.
- July 30, 2003: PNB informed Anna Marie it would not honor the two FXCTDs and would withhold the ₱250,741.82 balance, claiming prior unrecorded withdrawals totaling ₱251,246.81 against the consolidated account.
- Trial Court Proceedings (RTC, Civil Case No. Q-04-53432)
- Anna Marie filed for recovery of the unpaid balances and damages against PNB and branch manager Silverio Fernandez. PNB countered that it had paid (a) USD 10,058.01 under FXCTD No. 993902, (b) USD 10,718.87 under FXCTD No. 993992, and (c) offset ₱251,246.81 from the consolidated account by manager’s check purchases; it also pleaded contributory negligence.
- The RTC excluded PNB’s photocopied tickets, manager’s check, and out-of-court affidavit under the best‐evidence and hearsay rules. It found PNB failed to prove payment, awarded actual damages for the full balances, moral and exemplary damages, attorney’s fees, and costs.
- Court of Appeals Proceedings (CA-G.R. CV No. 96289)
- The CA reversed the RTC, admitting PNB’s SOA, manager’s check, miscellaneous ticket, and an affidavit of PNB’s New York officer. It held these proved payment of the disputed amounts and dismissed Anna Marie’s claims.
Issues:
- Whether Anna Marie is entitled to payment of:
- USD 10,058.01 under FXCTD No. 993902;
- USD 20,244.42 under FXCTD No. 993992;
- ₱250,741.82 under Savings Account No. 6121200.
- Whether Anna Marie is entitled to:
- Actual, moral, and exemplary damages;
- Attorney’s fees, costs of suit, and legal interest.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)