Case Digest (G.R. No. L-26001) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Philippine National Bank (PNB) vs. The Court of Appeals and Philippine Commercial and Industrial Bank (PCIB), G.R. No. L-26001, decided October 29, 1968, one Augusto Lim deposited GSIS Check No. 645915-B for ₱57,415.00, drawn on PNB, into his current account at PCIB’s Padre Faura Branch in Manila on January 15, 1962. Unaware that the signatures of the GSIS officers on the check were forged, PCIB stamped on its back “All prior indorsements and/or Lack of Endorsement Guaranteed, Philippine Commercial and Industrial Bank, Padre Faura Branch, Manila,” and forwarded it through the Central Bank for clearing. PNB neither returned the check nor refused payment the following day, but debited the GSIS account and paid PCIB. Upon GSIS’s demand and proof of forgery on January 31, 1962, PNB re-credited GSIS and on February 2, 1962, demanded reimbursement from PCIB, which refused. PCIB’s motion to dismiss was granted by the Court of First Instance of Manila and affirmed by the Court of App Case Digest (G.R. No. L-26001) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and transaction
- Petitioner Philippine National Bank (PNB) is drawee of GSIS Check No. 645915-B for P57,415.00.
- Respondent Philippine Commercial and Industrial Bank (PCIB) received the check after deposit by Augusto Lim.
- Notice of loss and stop-payment
- On November 13, 1961, GSIS notified PNB of the check’s loss and requested stoppage of payment; PNB acknowledged receipt.
- PNB failed to stop payment despite the formal notice.
- Processing and alleged forgery
- On January 15, 1962, PCIB forwarded the check through the Central Bank for clearing; PNB paid the check and debited GSIS.
- On January 31, 1962, GSIS demanded re-credit due to forgery of its officers’ signatures; PNB re-credited GSIS.
- Judicial proceedings
- PNB sued PCIB for refund of P57,415.00; the Court of First Instance of Manila dismissed the complaint.
- The Court of Appeals affirmed the dismissal; PNB sought certiorari review by the Supreme Court.
Issues:
- Was PCIB negligent in failing to detect the forgery?
- Are the indorsement signatures on the check forged?
- Is PCIB liable under its back-of-check warranty?
- Does “clearing” constitute “acceptance” under the Negotiable Instruments Law?
- Can PNB, as drawee, recover payment absent formal acceptance?
- Does PNB have a right to reimbursement from PCIB?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)