Title
Metropolitan Bank and Trust Co. vs. Chiok
Case
G.R. No. 172652
Decision Date
Nov 26, 2014
Chiok sued banks after Nuguid failed to deliver dollars post-check transactions. Courts ruled banks not liable; Chiok’s claim against Nuguid upheld. Global Bank ordered to pay BPI check value with interest.

Case Digest (G.R. No. 172652)
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    • Appeals – CA (May 5, 2006) affirmed with modifications: rescinded Chiok–Nuguid contract; canceled checks; ordered banks to credit Chiok’s accounts with principal plus reduced interest; sustained dismissal of BPI.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)

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