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
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. The events leading to the case began in 2010 when Vivian Caguimbal, a subcontractor of logs for the SAMMILIA Federation of People's Forest Development Cooperative, delivered logs to Baganga Plywood Corporation (Baganga Ply). In return, Baganga Ply issued six checks totaling PHP 3,494,129.50 to Vivian, which were drawn on PNB-Mati. On August 9, 2010, Vivian's daughter, Faith Caguimbal, visited the PNB-Butuan Branch to verify the status of these checks. She was informed by Sales and Service Officer Grace Besa that a Stop Payment Order (SPO) had been issued on the checks by Baganga Ply.
Despite this, on August 12, 2010, Faith presented the checks for deposit at the same branch, where they were accepted by Sales and Service Head Carlos S. Lim, Jr., who was unaware of the prior inquiry regarding the checks. On August 16, five of the checks were returned marked "SPO-funded," and the corresponding amounts were debited from the joint account of Vivian and Faith. However, the check for PHP 1,000,000.00 (Check No. 42399) was not returned immediately, leading the respondents to believe that the SPO had been lifted.
On August 19, Faith checked their account and found the PHP 1,000,000.00 still intact. However, on September 1, after withdrawing PHP 25,000.00, she discovered that the balance had dropped significantly due to the bank debiting the amount to implement the SPO. PNB later informed Vivian that the check had been cleared by mistake and that the SPO was only discovered after a complaint from Baganga Ply. Vivian filed a complaint against PNB after it refused to return the debited amount.
In its defense, PNB ...