Case Digest (G.R. No. 160727)
Facts:
On September 22, 1983, respondents Rosa Aquero, Gerard Yu, Eric Yu, Mina Yu, Elizabeth Ngkaion, Merly Cuescano, Leticia Tan, Fely Rumbana and Lorna Acub, through their attorney-in-fact John Francis Cotaoco, invested ₱10,000 each in money market placements with Premiere Financing Corporation (PFC). PFC issued promissory notes and checks which, upon presentation to PFC, were redirected to Regent Savings Bank (RSB). Instead of paying cash, RSB, with Cotaoco’s agreement, issued thirteen Certificates of Time Deposit (CTDs Nos. 09648–09660), each reflecting a ₱10,000 deposit, 14% per annum interest, maturity on November 3, 1983, and insurance coverage up to ₱15,000 by the Philippine Deposit Insurance Corporation (PDIC). On maturity, RSB requested an extension to pay, but ultimately failed and advised Cotaoco to claim with PDIC. Meanwhile, on June 15, 1984, the Central Bank suspended RSB’s operations and on December 7, 1984, ordered its liquidation. The CTDs were omitted from RSB’s masCase Digest (G.R. No. 160727)
Facts:
- Investment and issuance of certificates
- On September 22, 1983, private respondents, through their attorney-in-fact John Francis Cotaoco, invested ₱10,000 each in money market placements with Premiere Financing Corporation (PFC) and received corresponding promissory notes and checks.
- PFC referred Cotaoco to Regent Savings Bank (RSB), which, instead of cashing the notes and checks, issued 13 certificates of time deposit (CTDs Nos. 09648–09660) each certifying a ₱10,000 deposit at 14% per annum, insured up to ₱15,000 by PDIC, maturing November 3, 1983.
- Maturity, deferment, and bank closure
- On maturity (November 3, 1983), RSB sought a short extension to raise funds; Cotaoco agreed, but RSB still failed to pay and advised filing a claim with PDIC.
- On June 15, 1984, the Central Bank’s Monetary Board suspended RSB (Res. No. 788) and on December 7, 1984, ordered its liquidation (Res. No. 1496). RSB’s master list of liabilities omitted the CTDs as unfunded.
- Claims and judicial proceedings
- On September 4, 1984, private respondents filed deposit-insurance claims with PDIC, which were denied because the PFC check (Traders Royal Bank Check No. 299255 for ₱125,846.07) had bounced and was not replaced, leading to CTD cancellation by RSB.
- On March 31, 1987, respondents sued PDIC, RSB, and the Central Bank for collection. The trial court (May 29, 1989) held all defendants liable; the Court of Appeals (February 8, 1995) granted the Central Bank’s certiorari petition but affirmed liability of PDIC and RSB. PDIC then elevated the case to the Supreme Court.
Issues:
- Whether the CTDs are negotiable instruments under the Negotiable Instruments Law.
- Whether the CTDs were acquired for value and consideration.
- Whether PDIC is liable on the CTDs because they state on their face that they are insured.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)