Title
Philippine National Bank vs. Spouses Caguimbal
Case
G.R. No. 248821
Decision Date
Oct 10, 2022
PNB negligently handled a Stop Payment Order, debiting P1M from Vivian Caguimbal’s account without notice, leading to a Supreme Court ruling affirming damages for gross negligence.
Font Size:

Case Digest (G.R. No. 248821)

Facts:

Background of the Case:
Respondent Vivian Caguimbal was a sub-contractor for SAMMILIA Federation of People's Forest Development Cooperative (SAMMILIA), which supplied logs to Baganga Plywood Corporation (Baganga Ply). In 2010, Vivian delivered logs to Baganga Ply and received six PNB-Mati checks totaling P3,494,129.50.

Verification of Checks:
On August 9, 2010, Vivian’s daughter, Faith Caguimbal, inquired with PNB-Butuan Branch about the status of the checks. Grace Besa, a PNB officer, informed her that a Stop Payment Order (SPO) had been issued by Baganga Ply.

Deposit of Checks:
On August 12, 2010, the checks were presented for deposit by Jill Martirez, Faith’s cousin, to Carlos Lim, PNB-Butuan’s Sales and Service Head. Unaware of the SPO, Lim accepted the checks for clearing. Five checks were later returned with “SPO-funded” stamps, but one check (Check No. 42399 for P1,000,000.00) remained credited to the account.

Inquiries and Actions:
From August 16 to August 31, 2010, respondents observed that the P1,000,000.00 remained in their account, leading them to believe the SPO had been lifted. However, on September 1, 2010, the amount was abruptly debited without prior notice.

Dispute and Complaint:
Respondents filed a complaint for sum of money, damages, and attorney’s fees against PNB, alleging negligence in handling the SPO and the abrupt debit of P1,000,000.00.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Duty of Banks: Banks are held to the highest degree of diligence in handling clients’ accounts due to the fiduciary nature of their relationship. PNB failed to meet this standard by delaying the discovery of its mistake and debiting the account without prior notice.
  2. Negligence: PNB’s failure to promptly rectify the error and inform respondents constituted gross negligence, justifying the award of damages.
  3. Damages: Moral damages were awarded for the anxiety and humiliation suffered by respondents, while exemplary damages were imposed to serve as a warning to banks. Attorney’s fees were granted as respondents were compelled to litigate.


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.