Case Digest (G.R. No. 214567) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Dra. Mercedes Oliver v. Philippine Savings Bank and Lilia Castro (G.R. No. 214567, April 4, 2016), petitioner Dra. Mercedes Oliver maintained a savings account (No. 2812-07991-6) with respondent Philippine Savings Bank (PSBank). Respondent Lilia Castro was PSBank’s Acting Branch Manager in San Pedro, Laguna. Beginning in 1997, Oliver deposited ₱12 million and agreed to let Castro relay interim loans to borrowers at 4 percent monthly interest, with Castro earning a 10 percent commission. Pleased with the returns, Oliver secured an additional ₱10 million credit line—mortgaging her Ayala Alabang property (TCT No. 137796)—and instructed Castro to remit ₱2 million monthly from September 3, 1998, to January 3, 1999. In late 1998, Castro withheld Oliver’s passbook and made numerous erasures. A transaction register later revealed an unauthorized ₱4,491,250 loan credit and a ₱7 million debit on December 21, 1998, plus a ₱1,396,310.45 loan on January 5, 1999—none reflected in Oliver’s Case Digest (G.R. No. 214567) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Relationship and Financing Arrangement
- In 1997, Dr. Mercedes Oliver deposited ₱12,000,000.00 in PSBank; Lilia Castro (Assistant VP and Acting Branch Manager) proposed an “interim/bridge financing” scheme.
- Under the arrangement, Castro withdrew from Oliver’s account to lend to approved PSBank borrowers at 4% monthly interest; upon actual loan release, Castro returned principal plus interest to Oliver and received a 10% commission on interest.
- Disputed Loans, Passbook Alterations and Foreclosure
- Oliver secured a ₱10,000,000.00 credit line (mortgaging her Ayala Alabang property); instructed ₱2,000,000.00 monthly payments from September 1998. In December 1998 and January 1999, additional loans of ₱4,491,250.00 and ₱1,396,310.45 were posted; a ₱7,000,000.00 withdrawal also appeared. Oliver denied authorizing these transactions.
- Upon demand letters and notice of extrajudicial foreclosure, Oliver discovered multiple erasures in her passbook (held by Castro) and discrepancies with the Transaction History Register. She filed an injunction and damages suit against PSBank and Castro.
- Proceedings Below
- RTC (Mar. 30, 2010): Dismissed Oliver’s complaint; found loans valid and no proof of unauthorized withdrawal; lifted injunction.
- RTC (July 22, 2010): On reconsideration, granted Oliver’s motion; set aside dismissal; held withdrawal unauthorized; awarded actual, moral, exemplary damages and attorney’s fees; made injunction permanent.
- CA (Oct. 25, 2013): Reversed RTC July 22 order; reinstated RTC March 30 decision; deleted damages award; injunction lifted; denied Oliver’s motion for reconsideration (Sept. 12, 2014).
Issues:
- Whether the CA gravely erred in ruling that Oliver failed to show compelling evidence of fraud in the release of the ₱4.5 million loan and the ₱7 million withdrawal.
- Whether the CA gravely erred in ruling there was no evidence that the ₱7 million was debited without Oliver’s authorization.
- Whether the CA gravely erred in ruling that PSBank and Castro treated Oliver’s account with extraordinary diligence.
- Whether the CA gravely erred in not holding PSBank and Castro jointly and severally liable for damages.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)