Case Digest (G.R. No. 108052) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Philippine National Bank v. Court of Appeals and Ramon Lapez, decided on July 24, 1996 under the 1987 Constitution, petitioner Philippine National Bank (PNB) as local correspondent of the National Commercial Bank of Jeddah (NCB) intercepted two telegraphic fund transfers intended for private respondent Ramon Lapez (doing business as Sapphire Shipping). The first remittance of US$2,627.11 from NCB of Jeddah was to be credited to Lapez’s account with Citibank, Greenhills Branch, while the second foreign transfer from Libya was to be deposited in his PNB account No. 830-2410. Claiming an extra-contractual obligation under the principle of solutio indebiti, PNB offset these amounts against two prior erroneous double credits it had granted Lapez in November 1980 (US$5,679.23) and January 1981 (US$5,885.38), for a total overcredit of P87,380.44. Lapez demanded the return of US$2,627.11 by letter dated December 4, 1986, to which PNB replied on December 22 inviting a conference. PNB Case Digest (G.R. No. 108052) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Remittances
- Petitioner Philippine National Bank (PNB) acted as local correspondent of National Commercial Bank (NCB) of Jeddah, Saudi Arabia; respondent Ramon Lapez (Sapphire Shipping) was beneficiary.
- Two fund transfers were coursed through PNB:
- US$2,627.11 from NCB Jeddah intended for credit to Lapez’s Citibank Greenhills account.
- P34,340.38 from Brega Petroleum Marketing Company of Libya intended for deposit in Lapez’s PNB account No. 830-2410.
- Interception and Prior Erroneous Credits
- PNB intercepted the US$2,627.11 and applied it by way of compensation to recover two mistaken double credits (US$5,679.23 in November 1980 and US$5,885.38 in January 1981; aggregate P87,380.44) previously and erroneously credited to Lapez’s PNB account.
- Lapez made a written demand (Dec. 4, 1986) for release of US$2,627.11; PNB replied (Dec. 22, 1986) inviting conference. PNB issued receipt No. 857576 (Feb. 18, 1987) acknowledging P34,340.38 as “full settlement.”
- Trial Court Proceedings
- PNB pleaded compensation (Art. 1279, Civil Code) and solutio indebiti (Art. 2154) to justify interception and set-off. It also raised prescription of Lapez’s claim.
- The Regional Trial Court held:
- The mistaken double credits gave rise to a quasi-contractual obligation (solutio indebiti) of Lapez to refund PNB.
- No legal compensation for US$2,627.11: PNB was trustee, Lapez the beneficiary under stipulation pour autrui (Art. 1453).
- Compensation valid only for P34,340.38 (all requisites under Art. 1279 present); net indebtedness P7,380.44.
- PNB ordered to pay Lapez US$2,627.11 (or peso equivalent with interest from Jan. 13, 1987); all other claims and counterclaims dismissed.
- Court of Appeals Decision
- Affirmed trial court in toto:
- Held that the remittance created no creditor-debtor relation between PNB and Lapez; PNB’s sole duty was to transmit to Citibank.
- Found no legal ground to intercept US$2,627.11; upheld trust relationship.
- Confirmed entitlement to compensation for P34,340.38 only.
Issues:
- Compensation/Set-Off
- Whether PNB, as local correspondent bank, could legally intercept the US$2,627.11 remittance and apply it as compensation for Lapez’s previous indebtedness under Art. 1279 of the Civil Code.
- Whether the requirements for legal compensation (principal debts, sum of money, due, liquidated, no dispute) were present.
- Prescription
- Whether PNB’s claim to recover the mistaken double credits was barred by prescription (quasi-contract claims under Art. 1145, six-year period).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)