Case Digest (G.R. No. 88866) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Metropolitan Bank & Trust Company (“Metrobank”) v. Golden Savings & Loan Association, Inc. et al., decided on February 18, 1991 under the 1987 Constitution, a dispute arose over P1,755,228.37 in treasury warrants deposited by Eduardo Gomez with Golden Savings in Calapan, Mindoro. Gomez had deposited 38 warrants drawn by the Philippine Fish Marketing Authority, purportedly signed by its General Manager and countersigned by its Auditor. Six were payable directly to him; the rest bore successive indorsements ending with Gomez. Between June 25 and July 16, 1979, Golden Savings, through its Cashier Gloria Castillo, indorsed and deposited these warrants into its Metrobank Savings Account No. 2498. Metrobank sent them for special clearing but withheld crediting Gomez’s account until it purportedly confirmed their clearance. After repeated inquiries by Castillo, Metrobank—allegedly “exasperated” and wishing to accommodate a valued client—permitted Golden Savings to withdraw P968,000 Case Digest (G.R. No. 88866) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner Metropolitan Bank & Trust Company (Metrobank) is a commercial bank with branches nationwide.
- Respondents Golden Savings & Loan Association, Inc. (Golden Savings) and spouses Magno, Lucia, and Gloria Castillo operated a savings and loan association in Calapan, Mindoro.
- Deposit of Treasury Warrants
- In January–February 1979, Eduardo Gomez opened an account with Golden Savings, depositing 38 Philippine Fish Marketing Authority treasury warrants totaling ₱1,755,228.37; six payable directly to Gomez, the rest indorsed by prior payees and Gomez.
- Between June 25 and July 16, 1979, Gloria Castillo indorsed the warrants as Golden Savings’ cashier and deposited them to Golden Savings’ Metrobank Savings Account No. 2498 for special clearing through the Bureau of Treasury.
- Clearance Inquiries and Withdrawals
- After over two weeks, Gloria repeatedly inquired at Metrobank about clearance; Metrobank—allegedly exasperated—allowed Golden Savings to withdraw funds before actual payment, on July 9 (₱508,000), July 13 (₱310,000), and July 16 (₱150,000), totaling ₱968,000.
- Golden Savings in turn permitted Gomez to withdraw ₱1,167,500 from his account on the same dates.
- Dishonor and Lower Court Proceedings
- On July 19, 1979, the Bureau of Treasury dishonored 32 warrants; Metrobank notified Golden Savings on July 21 and demanded reimbursement, which was refused.
- Metrobank sued Golden Savings in the RTC of Mindoro, which on November 4, 1986, dismissed the complaint, ordered Metrobank to reverse its debit of ₱1,754,089, reinstate Golden Savings’ account, and awarded attorney’s fees to respondents.
- The Court of Appeals affirmed. Metrobank then filed this petition to the Supreme Court.
Issues:
- Whether Metrobank’s right to “charge back” under deposit‐slip conditions absolves it from liability for prematurely honoring deposits that were not actually cleared.
- Whether Golden Savings should bear the loss instead of Metrobank as between collecting bank and depositor.
- Whether the treasury warrants are negotiable instruments, entitling indorsers to holder‐in‐due‐course protections.
- Whether Metrobank’s negligence in implying clearance bars it from invoking contractual disclaimers.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)