Case Digest (G.R. No. L-150)
Facts:
- Vicente Hilado was a depositor at the Philippine National Bank.
- As of December 29, 1941, he had a credit balance of P3,687.21.
- During the Japanese occupation, he withdrew funds, leaving a balance of P578.37 by February 13, 1943.
- On February 18, 1943, he deposited P500 and made additional deposits totaling P93,250 throughout 1944.
- By December 26, 1944, his total credit balance was P15,023.01.
- Hilado sought to recover this entire balance, but the defendants claimed that Executive Order No. 49 rendered all deposits made during the occupation null and void.
- The lower court ruled that the Executive Order was valid but limited Hilado's recovery to P3,678.27, his pre-war balance, finding the Executive Order unconstitutional in its treatment of withdrawals and deposits.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that Executive Order No. 49 does not deprive Hilado of his property without due process or impair the bank's contractual obligations.
- The Court upheld the validity of the Executive Order concerning bank deposits in Japanese war notes.
- However, it reversed the lower court's judgment re...(Unlock)
Ratio:
- The Court emphasized the relationship between depositors and banks as one of creditor and debtor.
- It clarified that the payment of a depositor's check is a fulfillment of the bank's obligation, not a loan.
- Deposits made during the Japanese occupation were considered additional credits, not payments of pre-existing debts.
- The Executive Order's declaration that these deposits were null and void was deemed unjust, as it limited depositor rights while al...continue reading
Case Digest (G.R. No. L-150)
Facts:
The case of Vicente Hilado vs. Felix de la Costa, in his capacity as Acting Bank Commissioner, and the Philippine National Bank, was decided by the Supreme Court of the Philippines on April 30, 1949, under G.R. No. L-150. Vicente Hilado, the plaintiff-appellee, was a depositor at the Philippine National Bank. Prior to the Japanese occupation, Hilado had a credit balance of P3,687.21 as of December 29, 1941. During the occupation, he made several withdrawals from his account, which left him with a balance of P578.37 by February 13, 1943, without making any deposits during that period. On February 18, 1943, he deposited P500, and throughout 1944, he made additional deposits totaling P93,250. By December 26, 1944, his total credit balance amounted to P15,023.01. Hilado sought to recover this entire balance; however, the defendants contended that under Executive Order No. 49, all deposits made during the Japanese occupation were null and void. The lower court ruled that while the Executive Order was valid, it unjustly limited Hilado's recovery to the lowest minimum balance of P3,678.27, which was his pre-war balance. The court found that the Executive Order was unconstitutional in how it treated withdrawals as valid while deeming deposits void.
Issue:
- Is Executive Order No. 49 unconstitutional for declaring all deposits made during the Japanese occupation null and void while validating withdrawals fro...