Case Digest (G.R. No. 173780) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
This case involves Metropolitan Bank and Trust Company (Metrobank) as the petitioner and Marina B. Custodio, a bank teller of Metrobank’s Laoag City branch, as the respondent. The events occurred on June 13, 1995, when Custodio reported for work and was assigned as Teller No. 3. She received loose money (picos) for the day's transactions and handled several cash dealings with bank customers. At 12:10 pm, she received a cash transfer of PhP200,000 from another teller, though the bank acknowledged she already had sufficient cash on hand. At 12:25 pm, Custodio left for lunch alone, carrying a shoulder bag and paper bag, without these being inspected by the security guard, Hannibal Jara. At the day’s close, Custodio turned over PhP2,113,500 to the cash custodian, Marinel Castro, who signed a Cash Transfer Slip acknowledging receipt.
Later that afternoon, a shortage of PhP600,000 was discovered, leading the branch manager to instruct thorough reviews and searches, including insp
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Case Digest (G.R. No. 173780) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Parties
- Petitioner Metropolitan Bank and Trust Company (Metrobank) is a banking corporation.
- Respondent Marina B. Custodio was a teller at Metrobank’s Laoag City branch.
- Events of June 13, 1995
- Custodio reported for work at 8:18 a.m. and was assigned Teller No. 3.
- She received loose cash (picos) totaling PhP54,929.19 for the day’s transactions.
- Throughout the day, she handled numerous cash transactions with customers.
- At 12:10 p.m., a cash transfer of PhP200,000 was made from Teller No. 1 to Custodio, despite her having sufficient cash on hand (PhP1,139,874.32).
- At 12:25 p.m., Custodio took a lunch break alone, carrying a shoulder bag and paper bag, deviating from usual practice of taking lunch with co-tellers. The security guard noticed but did not inspect the bags.
- Discovery of Cash Shortage
- At the close of banking hours, Custodio balanced her cash and turned over PhP2,113,500 to the cash custodian, Ms. Marinel Castro, who signed the Cash Transfer Slip acknowledging receipt.
- At around 5:05 p.m., Ms. Castro discovered a shortage of PhP600,000, composed of PhP200,000 in one-thousand-peso bills and PhP400,000 in five-hundred-peso bills.
- The branch manager, Mr. Adriano Lucas, ordered a review of transactions and a search of employees’ desks and bags. The money was not found.
- Custodio left work with other employees at 8:30 p.m. that day.
- Investigation and Subsequent Developments
- Investigators from Metrobank’s regional and head offices conducted one-on-one interviews with employees including Custodio.
- Ms. Castro admitted signing the Cash Transfer Slip without counting the money.
- Polygraph tests were administered to employees except Custodio, who was eight months pregnant.
- On June 22, 1995, Metrobank filed a Complaint for a sum of money against Custodio, seeking recovery of PhP600,000 with attorney’s fees and costs.
- The trial court granted the writ of preliminary attachment on Custodio’s properties and served her summons on June 23, 1995.
- On the same day, Custodio was caught carrying a teller’s transaction journal slip related to June 23, 1995 transactions in her dress pocket; she explained it was mistakenly brought due to confusion after being served the complaint. No cash shortage was found on that day.
- Following this incident, Custodio was relegated to a non-accountable position and suspended for seven days without pay for "attempt to surreptitiously bring out bank records."
- Custodio requested a copy of the Cash Transfer Slip, but Metrobank did not act on the request and failed to present the slip as evidence despite assurances.
- Trial Proceedings and Appeals
- Custodio denied liability, asserting that the cash shortage occurred after she turned over the funds to Ms. Castro.
- Trial court ruled in favor of Metrobank, ordering Custodio to pay PhP600,000 plus interest.
- Custodio appealed, and on July 14, 2006, the Court of Appeals (CA) reversed the trial court decision and dismissed the complaint against Custodio.
- Metrobank filed a Motion for Extension of Time to file a Petition for Review in the Supreme Court, eventually filing it within extension. Custodio opposed the petition.
- Issues of Procedure Raised
- The issue whether factual questions may be reviewed under a Rule 45 Petition for Review on Certiorari.
- The legitimacy of a separate Petition for Review filed by Metrobank’s former counsel.
- Merits of the Case as Per Supreme Court’s Review
- The key issue is whether Custodio was proven liable for the PhP600,000 cash shortage.
- Metrobank bears the burden of proving by preponderance of evidence Custodio’s liability.
- Evidence failed to show that Custodio took the entrusted funds.
- Cash Transfer Slip, though not entered into evidence, was admitted to have been signed by Ms. Castro, indicating receipt of funds without shortage at handover.
- Ms. Castro admitted she did not count money before signing, constituting negligence contributing to the loss.
- Security guard Hannibal Jara observed Custodio left for lunch with bags but did not inspect them, which was a lapse.
- Metrobank failed to explain the discovery circumstances of eight bill wrappers stamped “PEPT-3” attributed to Custodio; no initials or timestamps were present; wrappers could have been easily fabricated.
- Metrobank did not demand restitution from Custodio prior to filing suit; she was allowed to continue her duties after the shortage.
- Custodio’s prior involvement in a cash shortage at Metrobank’s Cubao branch was introduced by Metrobank but deemed insufficient to prove liability for the Laoag shortage.
- Incident involving Custodio taking journal slip on June 23, 1995 was unrelated to the shortage occurring on June 13, 1995.
- Metrobank’s contention that the cash might have been taken after cash custodian’s turnover conflicted with their theory placing the shortage on June 13, 1995 morning.
- Procedural lapses among cash custodian and security guard opened multiple possibilities for the shortage, undermining certainty as to Custodio’s liability.
Issues:
- Procedural Issues
- Whether the Supreme Court may review factual issues raised in a Rule 45 Petition for Review on Certiorari.
- Whether separate Petition filed by Metrobank’s former counsel, without proof of payment or official filing, should be considered.
- Substantive Issue
- Whether the evidence on record sufficiently establishes that respondent Custodio incurred and is liable for the cash shortage of PhP600,000.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)