Case Digest (G.R. No. 221220)
Facts:
Metropolitan Bank and Trust Company v. Carmelita Cruz and Vilma Low Tay, G.R. No. 221220, January 19, 2021, the Supreme Court First Division, Gaerlan, J., writing for the Court. Petitioner-bank Metrobank sought review of the Court of Appeals' February 23, 2015 Decision and October 21, 2015 Resolution in CA‑G.R. CV No. 99886, which had affirmed the September 21, 2012 Decision of the Regional Trial Court (RTC), Branch 192, Marikina City, ordering Metrobank to render a complete accounting of payments made by respondents Carmelita Cruz and Vilma Low Tay (doing business as Republic Shoes & Handbag Manufacturing) and to furnish copies of their loan documents.From 1993 to 1998 respondents obtained loans from Metrobank aggregating P40,600,000 and executed promissory notes; they obtained additional loans in March 1999. In May 1999 Metrobank sent a statement that respondents owed P1,130,444.31 as of March 26, 1999. Over the years the loans were restructured and respondents signed bulk blank promissory notes. Between 1999 and 2004 respondents made cash and check payments, kept informal payment lists (yellow sheets) and sought acknowledgments from bank employees.
In September–October 2004 respondents discovered a possible overpayment and asked for a statement of account. Metrobank supplied a Summary on Application of Payments (SAP) showing an outstanding obligation of P8,344,185.55 as of September 2004. Respondents engaged accountant Michael Palisoc who reviewed the SAPs, promissory notes, receipts and checks and concluded respondents paid P32,648,374.60 while Metrobank recorded only P20,507,855.05 — an unaccounted P12,140,519.55; after deducting a restructured balance Palisoc found an overpayment of P3,540,519.55 as of September 21, 2004. He also noted delayed recording of payments, missing receipts, an unrecorded dacion en pago, and unrecorded checks.
After repeated demands for reconciliation and refund, respondents filed a complaint for accounting before the RTC on May 4, 2005, seeking production of loan records and reimbursement for overpayment with damages. Metrobank answered and counterclaimed, asserting it had provided a concise accounting, that some documents were beyond its retention period, that subsequent loan documents superseded prior ones, and that respondents were estopped by acknowledging indebtedness in later promissory notes; it sought damages and attorney’s fees on its counterclaim.
The RTC, in a September 21, 2012 Decision, directed Metrobank to render a complete and detailed accounting for 1993–2004, to furnish copies of all promissory notes and loan documents for the same period, and dismissed Metrobank’s counterclaim. Metrobank appealed to the Court of Appeals. The C...(Pro-only)
Issues:
- In a Rule 45 petition, may the Supreme Court review alleged factual errors and reweigh evidence presented below?
- Should Metrobank be ordered to render a full and detailed accounting of respondents’ payments covering 1993–2004?
- Should Metrobank be ordered to furnish respondents all pertinent loan documents for the same period despite its five‑y...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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