Case Digest (G.R. No. 183204)
Facts:
The Metropolitan Bank and Trust Company v. Ana Grace Rosales and Yo Yuk To, G.R. No. 183204, January 13, 2014, Supreme Court Second Division, Del Castillo, J., writing for the Court.Petitioner is The Metropolitan Bank and Trust Company (MBTC); respondents are Ana Grace Rosales (owner/manager of China Golden Bridge Travel Services) and her mother Yo Yuk To. In 2000 respondents opened a Joint Peso Account with MBTC’s Pritil‑Tondo branch; as of August 4, 2004 the balance was P2,515,693.52. On March 3, 2003 respondents opened a Joint Dollar Account with MBTC (initial deposit US$14,000). On July 31, 2003 MBTC issued a Hold Out order against respondents’ accounts.
MBTC alleged that respondent Rosales and an unidentified woman were responsible for the unauthorized withdrawal of US$75,000.00 from a third party, Liu Chiu Fang’s dollar account at MBTC’s Escolta branch; MBTC later filed a criminal complaint for estafa (I.S. No. 03I‑25014) on September 3, 2003. MBTC also claimed that certain serial numbers of dollar notes deposited by respondents matched those withdrawn by the impostor. Rosales denied participation and testified to a different sequence of events: she acted as interpreter when Liu opened her account, later discovered Liu’s account had been closed without Liu’s knowledge, and only then informed bank officers and Liu. The Office of the City Prosecutor initially dismissed MBTC’s criminal complaint on December 15, 2003; MBTC moved for reconsideration and the dismissal was later reversed, an Information being filed in 2005.
On September 10, 2004 respondents filed Civil Case No. 04‑110895 before the Regional Trial Court (RTC) of Manila, Branch 21, for breach of obligation and contract and damages, praying that the Hold Out be lifted and that they be allowed to withdraw their deposits, and claiming actual, moral, and exemplary damages and attorneys’ fees. MBTC defended, asserting a valid basis for the Hold Out under the “Authority to Withhold, Sell and/or Set Off” (the “Hold Out clause”) in the Application and Agreement for Deposit Account and pointing to the alleged fraud and the criminal complaint.
On January 15, 2007 the RTC (Branch 21) rendered judgment for respondents, ordering MBTC to allow withdrawal of deposits with agreed interest and awarding actual damages of P50,000, moral damages of P50,000, exemplary damages of P30,000 and attorneys’ fees equal to 10% of the amount due; MBTC’s counterclaim was dismissed. MBTC appealed.
On April 2, 2008 the Court of Appeal...(Pro-only)
Issues:
- Did the Court of Appeals err in ruling that the Hold Out provision in MBTC’s Application and Agreement for Deposit Account does not apply in this case?
- Did the Court of Appeals err in ruling that MBTC’s employees were negligent in releasing Liu Chiu Fang’s funds?
- Did the Court of Appeals err in affirming the award of moral damages, exemplary damages, and ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)