G.R. No. 183204 - Metropolitan Bank and Trust Co. vs. Rosales

Account Opening and Balances
In 2000, respondents Ana Grace Rosales and Yo Yuk To opened Joint Peso Account No. 224-322405145-0 with petitioner Metropolitan Bank and Trust Company (MBTC), Pritil-Tondo Branch; as of August 4, 2004, the balance was ₱2,515,693.52.
On March 3, 2003, they opened Joint Dollar Account No. 0224-01041-0 with an initial deposit of US$14,000.00.

Hold-Out Order and Criminal Complaint
On July 31, 2003, MBTC issued a “Hold-Out” order against respondents’ peso and dollar accounts without notifying them of any obligation.
On September 3, 2003, MBTC filed a criminal complaint for estafa (I.S. No. 03I-25014) against Rosales, alleging she aided an impostor in withdrawing US$75,000.00 from client Liu Chiu Fang’s dollar account at the Escolta Branch.

Respondents’ Version and PLRA Proceedings
Rosales denied involvement, claiming she first learned of the withdrawal on February 6, 2003, when she accompanied a client to the bank and received a copy of a PLRA Withdrawal Clearance.
On June 23–24, 2003, at the Philippine Retirement Authority (PLRA), Liu Chiu Fang discovered the clearance was based on a Special Power of Attorney she never executed.

Criminal and Civil Proceedings
December 15, 2003: City Prosecutor of Manila dismissed the estafa complaint for lack of probable cause; MBTC’s motion for reconsideration ensued and the complaint was later reinstated on February 18, 2005.
September 10, 2004: Respondents filed a Complaint for Breach of Obligation and Contract with Damages (Civil Case No. 04-110895, RTC Manila, Branch 21), seeking release of deposits with interest, plus actual, moral, exemplary damages, and attorney’s fees.

Trial and Appeals
January 15, 2007: RTC rendered judgment finding MBTC liable for breach of contract; ordered release of deposits with agreed interest and awarded P50,000 moral, P30,000 exemplary damages, 10% attorney’s fees; dismissed MBTC’s counterclaim.
April 2, 2008: Court of Appeals (CA) affirmed RTC but deleted award of actual damages; May 30, 2008: CA denied MBTC’s motion for reconsideration.
MBTC then filed this Petition for Review on Certiorari under Rule 45.

Whether the “Hold-Out” provision in the deposit account agreement applied to respondents’ accounts.
Whether MBTC’s employees were negligent in releasing Liu Chiu Fang’s funds to an impostor.
Whether the CA erred in affirming the awards of moral damages, exemplary damages, and attorney’s fees.