Case Digest (G.R. No. 172652) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1995, Wilfred N. Chiok (respondent) engaged in longstanding dollar‐for‐peso transactions with Gonzalo B. Nuguid. To finance these deals, Chiok maintained accounts with Metropolitan Bank & Trust Company (Metrobank) and Global Business Bank, Inc. (formerly Asian Banking Corporation) and entered into a Bills Purchase Line Agreement (BPLA) with the latter. On July 5, 1995, pursuant to the BPLA, Asian Bank purchased a Security Bank manager’s check for ₱25,500,000 credited to Chiok’s account, and, on Chiok’s instructions, issued two manager’s checks totaling ₱18,455,350 to Nuguid’s name, debiting Chiok’s credited funds. Metrobank likewise issued a cashier’s check for ₱7,613,000 to Nuguid, drawn on Chiok’s Metrobank account. Chiok deposited these three checks (aggregate ₱26,068,350) into Nuguid’s account with Far East Bank & Trust Company (FEBTC, now Bank of the Philippine Islands or BPI), expecting delivery of US$1,022,288.50 that afternoon. When Nuguid failed to deliver the dollar Case Digest (G.R. No. 172652) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Wilfred N. Chiok (Chiok) – dollar trader; maintained accounts with Metropolitan Bank and Trust Company (Metrobank) and Asian Banking Corporation (now Global Business Bank, Inc. or Global Bank).
- Gonzalo B. Nuguid – supplier of dollars to Chiok under a long‐standing arrangement; deposited proceeds in his account at Far East Bank & Trust Company (FEBTC, now Bank of the Philippine Islands or BPI).
- Asian Bank – had a Bills Purchase Line Agreement (BPLA) with Chiok for purchasing checks.
- July 5–6, 1995 Transactions
- Asian Bank purchased SBTC MC No. 037364 (₱25,500,000) for Chiok and credited his account.
- Pursuant to Chiok’s instructions, Asian Bank issued two manager’s checks (Nos. 025935 for ₱7,550,000; 025939 for ₱10,905,350) to Nuguid, debiting Chiok’s account.
- Metrobank issued cashier’s check No. 003380 (₱7,613,000) to Nuguid, also debiting Chiok’s account.
- Chiok deposited the three checks (total ₱26,068,350) into Nuguid’s FEBTC account; Nuguid failed to deliver US$1,022,288.50 that afternoon.
- Procedural History
- July 6, 1995 – Chiok filed a complaint and secured an ex parte TRO/preliminary injunction against Nuguid, Asian Bank, and Metrobank to stop payment on the checks.
- Banks initially complied; FEBTC allowed Nuguid to withdraw proceeds on July 5, 1995. FEBTC filed an arbitration claim against Asian Bank, which was refused jurisdiction.
- July 25, 1995 – RTC issued preliminary prohibitory injunction upon Chiok’s bond; permanent injunction later after bond posting.
- October 18, 1995 – FEBTC intervened, claiming direct obligation of Asian Bank.
- August 29, 2002 – RTC rendered decision: confirmed injunction; ordered Global Bank and Metrobank to refund Chiok with interest and attorney’s fees; dismissed BPI’s intervention.
- Appeals – CA (May 5, 2006) affirmed with modifications: rescinded Chiok–Nuguid contract; canceled checks; ordered banks to credit Chiok’s accounts with principal plus reduced interest; sustained dismissal of BPI.
- May 28, 2013 – Metrobank, Global Bank, and Chiok jointly moved to dismiss proceedings as settled; BPI opposed.
- Supreme Court consolidated petitions by Metrobank, BPI, and Global Bank for review.
Issues:
- Whether a purchaser of a manager’s or cashier’s check may stop payment by court order due to alleged breach of contract by the payee (absence of consideration).
- Whether rescission under Civil Code Art. 1191 can apply against banks that issued and pre-accepted such checks.
- Whether the banks had knowledge of facts defeating the payee’s title to the checks.
- Whether Metrobank erred in paying the cashier’s check in defiance of the TRO.
- Whether BPI, as intervenor/collecting bank, may recover from Global Bank absent indorsement and holder-in-due-course status.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)