Title
Philippine National Bank vs. Spouses Caguimbal
Case
G.R. No. 248821
Decision Date
Oct 10, 2022
The Philippine National Bank is ordered to pay damages and attorney's fees due to negligent handling of a joint account causing financial losses to the account holders.
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Case Digest (G.R. No. 248821)

Facts:

  • The case involves the Philippine National Bank (PNB) as the petitioner and Spouses Pedro Caguimbal and Vivian Caguimbal as the respondents.
  • In 2010, Vivian Caguimbal, a subcontractor, delivered logs to Baganga Plywood Corporation (Baganga Ply) and received six checks totaling PHP 3,494,129.50.
  • These checks were drawn on PNB-Mati.
  • On August 9, 2010, Vivian's daughter, Faith Caguimbal, inquired about the checks at PNB-Butuan Branch and learned that a Stop Payment Order (SPO) had been issued by Baganga Ply.
  • Despite this, on August 12, Faith presented the checks for deposit, which were accepted by PNB staff unaware of the SPO.
  • On August 16, five checks were returned marked "SPO-funded," and the amounts were debited from Vivian and Faith's joint account.
  • The check for PHP 1,000,000.00 (Check No. 42399) was not returned immediately, leading the respondents to believe the SPO was lifted.
  • On September 1, after a withdrawal, Faith discovered the bank had debited the amount due to the SPO.
  • PNB later informed Vivian that the check had been cleared by mistake, prompting her to file a complaint after PNB refused to return the debited amount.
  • PNB argued that the respondents had no cause of action as they were aware of the SPO.
  • The Regional Trial Court (RTC) dismissed the complaint, but the Court of Appeals (CA) ruled in favor of the respondents, awarding them damages and attorney's fees.

Issue:

  • (Unlock)

Ruling:

  • The Court ruled that PNB had the right to debit the amount due to the SPO but acted with gross negligence by not notifying the respondents beforehand.
  • The Court upheld the CA's decision to aw...(Unlock)

Ratio:

  • The Supreme Court highlighted that banks must exercise a higher degree of diligence due to their fiduciary relationship with depositors.
  • PNB's actions were considered grossly negligent for failing to monitor the check's status and not promptly informing the respondents about its dishonor.
  • The bank's claim of acting without fraud or bad faith did not exempt it from liability, as...continue reading

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