Case Digest (G.R. No. L-18343) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Philippine National Bank, et al. v. Emilio A. Gancayco, et al. (122 Phil. 503, G.R. No. L-18343, September 30, 1965), special prosecutors Emilio A. Gancayco and Florentino Flor of the Department of Justice required the Philippine National Bank (PNB) to produce on February 20, 1961, the deposit records of Ernesto T. Jimenez, then under investigation for unexplained wealth as former administrator of the Agricultural Credit and Cooperative Administration. PNB declined, invoking Republic Act No. 1405 (September 9, 1955), which deems all deposits “absolutely confidential” except upon depositor’s written consent, impeachment, court order in bribery or dereliction of duty, or when deposit is the subject matter of litigation, and warned of penalties under Section 5 for unauthorized disclosure. The prosecutors countered with Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act, August 17, 1960), specifically Section 8, mandating that bank deposits be considered in enforcing cha Case Digest (G.R. No. L-18343) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Court Below
- Plaintiffs and Appellants: Philippine National Bank (PNB) and its president, Eduardo Z. Romualdez.
- Defendants and Appellees: Emilio A. Gancayco and Florentino Flor, special prosecutors of the Department of Justice.
- Underlying Transaction and Demand
- Investigated Person: Ernesto T. Jimenez, former administrator of the Agricultural Credit and Cooperative Administration, under investigation for unexplained wealth.
- Prosecutorial Demand: On February 20, 1961, at a scheduled hearing, defendants required PNB to produce Jimenez’s deposit records.
- Invoked Statutory Provisions
- Republic Act No. 1405 (Bank Secrecy Law)
- Section 2: Declares all bank deposits “absolutely confidential” except upon depositor’s written consent, impeachment, court order in bribery/dereliction cases, or when deposit is subject matter of litigation.
- Section 5: Penalizes disclosure with imprisonment or fine.
- Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act)
- Section 8: Declares that unexplained wealth—“manifestly out of proportion” bank deposits—shall be ground for dismissal and “shall be taken into consideration,” notwithstanding any law to the contrary.
- Procedural History
- PNB’s Response: Filed a declaratory relief action in the Manila Court of First Instance to enjoin enforcement of the production order.
- Trial Court Judgment: Held that Section 8 of RA 3019 amended Section 2 of RA 1405 by adding an exception, thus compelling disclosure. Plaintiffs appealed.
Issues:
- Does Section 8 of the Anti-Graft and Corrupt Practices Act (RA 3019) implicitly repeal or amend the confidentiality provision of Section 2 of RA 1405, thereby authorizing compulsory disclosure of bank deposit records in unexplained wealth investigations?
- Does compelling disclosure of deposit records contravene the policy of bank secrecy enshrined in RA 1405?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)