G.R. No. 221220 - Metropolitan Bank and Trust Co. vs. Cruz

Loan origination and restructuring
From 1993 to 1998, respondents Carmelita Cruz and Vilma Low Tay obtained various loans from Metrobank totalling P40,600,000.00 and executed promissory notes covering said loans.
In March 1999, they obtained additional loans; Metrobank’s May 17, 1999 letter stated an outstanding balance of P1,130,444.31 as of March 26, 1999.
Over the years, the loans were restructured and respondents signed blank promissory notes in bulk.

Payment history and discovery of discrepancies
Between 1999 and 2004, respondents made cash and check payments, recorded on yellow sheets acknowledged by bank employees.
In September 2004, they requested a new statement; Metrobank sent a Summary on Application of Payments (SAP) showing an outstanding P8,344,185.55 as of September 2004.
Accountant Michael G. Palisoc reviewed SAPs, original receipts, checks, and yellow sheets, finding total payments of P32,648,374.60 but recorded payments of only P20,507,855.05—an unaccounted P12,140,519.55, leading to an overpayment of P3,540,519.55 after adjustments.
Palisoc noted questionable practices: delayed recording of payments (increasing interest), unaccounted dacion en pago, missing receipts, and unreconciled check entries.

Procedural history
Respondents repeatedly demanded a detailed accounting and refund; Metrobank failed to comply and insisted on the P8,344,185.55.
On May 4, 2005, respondents filed a complaint for accounting in the RTC, praying for production of all loan records, reimbursement of overpayment, and damages.
Metrobank answered on June 10, 2005, denied discrepancies, claimed compliance, relied on estoppel (latest promissory note), and counterclaimed for damages and attorney’s fees.
RTC Decision dated September 21, 2012 ordered Metrobank to render a complete accounting from 1993 to 2004, furnish all promissory notes and loan documents for that period, and dismissed the counterclaim.
On February 23, 2015, the CA affirmed the RTC’s decision, rejected Metrobank’s retention-policy and estoppel defenses, and remanded for proper accounting.
Metrobank filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.

Accounting obligation
Should Metrobank be ordered to render a full and detailed accounting of respondents’ payments from 1993 to 2004?
Did Metrobank already provide a true and complete accounting?

Production of documents
Must Metrobank furnish all promissory notes and loan documents signed by respondents between 1993 and 2004?
Is such production impossible because of Metrobank’s five-year document-retention policy under the AMLA and Banking Manual?

Estoppel and burden of proof
Are respondents estopped from contesting the outstanding balance by virtue of subsequent promissory notes acknowledging indebtedness?
Does the burden rest on respondents to prove full payment?

Claim for damages
Is Metrobank entitled to moral and exemplary damages and attorney’s fees for what it alleges is a baseless suit that impeded its collection rights?