Case Digest (G.R. No. L-29432) Core Legal Reasoning Model
Facts:
This case involves a dispute between Jai-Alai Corporation of the Philippines (petitioner) and the Bank of the Philippine Islands (respondent) arising from the deposit of ten checks totaling P8,030.58 between April 2 and May 18, 1959, into the petitioner’s current account with the respondent bank. These checks, drawn by various entities upon different banks and payable to Inter-Island Gas Service, Inc., had been acquired by the petitioner from Antonio J. Ramirez, a sales agent of the Inter-Island Gas who was a regular bettor at Jai-Alai. Upon deposit, the respondent provisionally credited the petitioner’s account as stipulated in the deposit slips, which allowed the bank to debit the account if the proceeds were not actually received.
Later, Inter-Island Gas discovered the endorsements on the checks were forged by its supposed cashiers. After notifying the parties involved, including the petitioner and respondent, the respondent returned the checks to the drawee-banks and reimbu
Case Digest (G.R. No. L-29432) Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Jai-Alai Corporation of the Philippines (petitioner) deposited ten checks with a total face value of P8,030.58 in its current account at the Bank of the Philippine Islands (respondent) between April 2, 1959, and May 18, 1959.
- The checks were drawn by various entities (§ Delta Engineering Service, Enrique Cortiz & Co., Luzon Tinsmith & Co., Roxas Manufacturing, Inc.) and payable to Inter-Island Gas Service, Inc. or order/bearer.
- Source and Nature of Checks
- The petitioner had acquired the checks from Antonio J. Ramirez, a sales agent of Inter-Island Gas and a regular bettor at jai-alai games.
- Upon deposit, the respondent temporarily credited the amounts to petitioner’s account per a printed clause on deposit slips, reserving the right to charge back any item until actual receipt of funds.
- Discovery of Forgery and Consequences
- In late July 1959, Inter-Island Gas discovered the indorsements on the checks (by its cashiers Santiago Amplayo and Vicenta Mucor) and the corporate rubber stamp were forged.
- Inter-Island Gas notified petitioner, respondent, drawers, and drawee-banks and filed criminal charges against Ramirez (later dropped).
- In response to a letter from Inter-Island Gas dated August 31, 1959, respondent’s cashier informed petitioner it would debit its account for the checks once returned by drawee-banks.
- The drawee-banks returned the checks and demanded reimbursement from the respondent, who paid them and debited petitioner’s account accordingly. The petitioner refused to accept the debited checks.
- The Dishonored Check Incident and Subsequent Action
- On October 8, 1959, petitioner’s check for P135,000 was dishonored due to insufficient funds after netting the P8,030.58 debit from the forged checks.
- Petitioner filed suit against the respondent in the Court of First Instance, which dismissed the complaint; the Court of Appeals affirmed the dismissal.
- Petitioner elevated the case by filing a petition for review before the Supreme Court.
Issues:
- Whether respondent had the right to debit petitioner’s account for the total value of checks with forged indorsements more than three months after crediting them.
- Whether respondent was estopped from claiming non-credit of P8,030.58 since drawee-banks paid the respondent and the respondent received the funds in due course.
- Assuming the debit was improper, whether petitioner is entitled to damages against respondent.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)