Case Digest (G.R. No. 97995)
Facts:
In Philippine National Bank v. Court of Appeals and B.P. Mata & Co., Inc. (G.R. No. 97995, January 21, 1993), the petitioner, Philippine National Bank (PNB), challenged the dismissal of its refund claim against the respondent, B.P. Mata & Co., Inc. (Mata), a crewing agent for Star Kist Foods, Inc. Since 1966, Mata advanced crew expenses and billed Star Kist, which reimbursed via telegraphic transfers through U.S. banks. On February 21, 1975, Security Pacific National Bank in Los Angeles, acting through PNB, transmitted an instruction to credit Mata’s account with US$14,000. PNB caught the error on February 24 and obtained corrected instructions to pay only US$1,400, which was duly advanced on February 25. Nonetheless, on March 11, 1975, PNB mistakenly issued a second cashier’s check for US$14,000 to Mata. Six years later, upon discovering the error, PNB requested reimbursement and filed suit on February 4, 1982, invoking a constructive trust under Article 1456 of the Civil Code.Case Digest (G.R. No. 97995)
Facts:
- Parties and nature of transaction
- Private Respondent B.P. Mata & Co., Inc. (Mata) is a crewing agent for shipping firms, including Star Kist Foods, Inc. (Star Kist).
- Mata advances medical fees, seamen’s board fees, welfare fund contributions and personal needs of ship crew, billing Star Kist monthly for reimbursement.
- Telegraphic instructions and double payment
- On February 21, 1975, Security Pacific National Bank (SEPAC) of Los Angeles cabled Philippine National Bank (PNB) to credit US$14,000 to Mata’s account per Star Kist’s order.
- PNB detected a presumed error, inquired, and received correction that the amount due was only US$1,400; on February 25, 1975, PNB issued Cashier’s Check No. 269522 for US$1,400 through Insular Bank of Asia and America (IBAA).
- Despite the correction, on March 11, 1975 PNB again issued Cashier’s Check No. 270271 for US$14,000 to Mata, purporting to be another Star Kist reimbursement.
- Procedural history
- PNB discovered the second payment error on May 13, 1981 and requested refund of US$14,000.
- On February 4, 1982, PNB filed a civil action for collection and refund of the US$14,000, invoking a constructive trust under Article 1456 of the Civil Code.
- The Regional Trial Court dismissed the complaint, ruling that Mata’s obligation arose under quasi-contract (solutio indebiti, Art. 2154) and that the six-year prescription period (Art. 1145) had lapsed.
- The Court of Appeals affirmed the dismissal on the same grounds. PNB then filed this petition for certiorari.
Issues:
- Whether the obligation of Mata to return the US$14,000 is governed by a constructive trust under Article 1456 or by solutio indebiti under Article 2154 of the Civil Code.
- Whether PNB’s cause of action for refund is barred by prescription.
- Whether, even under a constructive trust theory, PNB’s claim is barred by laches.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)