Case Digest (G.R. No. 200407)
Facts:
Land Bank of the Philippines v. Gualberto Catadman, G.R. No. 200407, June 17, 2020, Supreme Court Third Division, Gaerlan, J., writing for the Court.On March 21, 1999, Land Bank of the Philippines (petitioner) received three checks drawn on the Development Bank of the Philippines, Mati Branch, endorsed through Land Bank’s Bajada/Davao branches: DBP Check No. 1731263 (P8,500) payable to GCNK Merchandising (owned by respondent Gualberto Catadman), DBP Check No. 151837 (P100,000) payable to NEDA–Regional Office XI, and DBP Check No. 358896 (P6,502.68) payable to Benjamin S. Reyno. All three checks were cleared on May 26, 1999.
Two days after clearing, due to handling errors, NEDA’s and Reyno’s checks were erroneously credited to Catadman’s account, and Catadman’s own check was credited twice, resulting in total erroneous credits of P115,062.68 to his account. Land Bank discovered the erroneous credits on June 25, 2001, and thereafter sent demand letters seeking return of the amounts; Catadman did not comply initially.
In a February 11, 2002 letter Catadman acknowledged receipt and stated he had spent the funds but promised to pay P2,000 monthly. He made payments totaling P15,000 but later stopped. After further demands failed, Land Bank filed a collection suit in the Municipal Trial Court in Cities (MTCC), Davao City.
The MTCC dismissed the complaint, holding the obligation to reimburse was a natural obligation, not enforceable as a civil obligation, and that Land Bank should pursue its negligent employee. Land Bank appealed to the Regional Trial Court (RTC), which reversed the MTCC, applying Articles 19, 22, and 1456 of the Civil Code and ordering Catadman to pay P100,002.68 plus legal interest from June 1, 2001.
Catadman then filed a petition for review with the Court of Appeals (CA). The CA (March 18, 2011 Decision, with a January 25, 2012 Resolution denying reconsideration) accepted that Land Bank’s employee was negligent and emphasized the fiduciary nature of banking; applying prior decisions such as BPI Family Bank v. Franco and Simex International (Manila), Inc. v. CA, the CA apportioned liability under a 60–40 ratio, holding Land Bank liable for 60% of the loss and Catadman liable for 40% (less the P15,000 he had paid), and remanded to ...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in not affirming in toto the RTC decision that reversed and set aside the MTCC judgment?
- Did the Court of Appeals err in refusing to hold Catadman liable for the full amount mistakenly credited despite finding unjust enric...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)