Case Digest (G.R. No. 190359)
Facts:
This case involves Primitiva M. Manalo (the respondent), who sold her property in Timog, Quezon City to Transit Automotive Supply. As payment, Transit issued five checks payable to Manalo between June and December 1992, which were deposited by Manalo and her authorized representative, her niece Veronidia C. Saturnino, under a Special Power of Attorney (SPA) executed on June 26, 1992. The SPA granted Saturnino authority to collect rentals and other accounts due Manalo and deposit them in authorized banks but did not explicitly authorize withdrawals or investments. Saturnino deposited three PCI Bank checks into Manalo’s accounts or investment vehicles but later diverted funds by investing the proceeds through Gensu Capital Management Corporation (GENSCOR), contrary to the SPA’s limitations. Manalo discovered these unauthorized withdrawals and misappropriations upon her return from the United States in 1995 and filed suit for recovery of funds and damages. The Regional Trial CourtCase Digest (G.R. No. 190359)
Facts:
- Parties and Nature of the Case
- Premiere Development Bank (Premiere Bank), Asian Bank Corporation (Asian Bank), and BDO Unibank, Inc. (formerly Equitable PCI Bank, PCI Bank) were petitioners.
- Primitiva M. Manalo, heirs of Veronidia C. Saturnino, Gensu Capital Management Corporation (GENSCOR), Equitable PCI Bank (now BDO), and Asian Bank Corporation (now Metropolitan Bank and Trust Company) were respondents.
- The case stems from allegations of unauthorized withdrawal and mismanagement of funds in Manalo's bank accounts resulting in damages.
- Factual Background
- Primitiva Manalo sold a property to Transit Automotive Supply, which paid via five checks issued by PCI Bank (now BDO) totaling P17,000,000.00.
- Manalo opened a savings account with PCI Bank and deposited two checks; the remaining three checks were entrusted to her niece, Veronidia Saturnino, under a Special Power of Attorney (SPA) authorizing her to collect rents and other accounts and deposit them.
- Saturnino deposited three PCI Bank checks (Nos. 315676, 315677, 315678) in different banks and manipulated the funds:
- Check No. 315676: Deposited with PCI Bank, proceeds split between savings and time deposit, later rolled over to a trust fund, then pre-terminated by Saturnino instructing PCI Bank to issue a manager's check payable to Manalo but given to Saturnino.
- Check No. 315677: Deposited in Asian Bank, proceeds allocated between savings, a common trust fund, and Asian Bank Capital Investment Corporation placement; manager's checks also made payable to Manalo were issued but ended with Saturnino investing the checks via GENSCOR.
- Check No. 315678: Deposited directly by Saturnino into GENSCOR's account with Premiere Bank.
- Development and Dispute
- Manalo returned to the Philippines in 1995 and discovered withdrawals and investments made by Saturnino without her authorization.
- Saturnino claimed she acted under SPA and Manalo's instructions; banks denied liability or fault.
- Premiere Bank, PCI Bank, and Asian Bank were sued for damages; the RTC found banks liable for negligence and ordered repayment with interest.
- The Court of Appeals (CA) affirmed the RTC decision.
- The banks filed separate petitions for review with the Supreme Court, contesting their liabilities.
Issues:
- Whether the banks (PCI Bank, Asian Bank, and Premiere Bank) were negligent in allowing withdrawals and deposits involving Manalo's checks and funds without proper authorization.
- Whether the Special Power of Attorney granted Saturnino authority to withdraw, invest, or otherwise manage Manalo's funds beyond collection and deposit.
- The extent of each bank's liability, especially the collecting bank (Premiere Bank) regarding the crossed checks deposited to accounts other than Manalo’s.
- Whether the banks may recover from Saturnino or GENSCOR for the amounts paid out due to negligence or fraud.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)