Case Digest (G.R. No. 115324)
Facts:
In Producers Bank of the Philippines v. Hon. Court of Appeals and Franklin Vives, private respondent Franklin Vives, on May 9, 1979, deposited ₱200,000.00 in Savings Account No. 10-1567 opened in the name of Sterela Marketing and Services at the Buendia, Makati branch of Producers Bank of the Philippines upon the assurances of Angeles Sanchez and Col. Arturo Doronilla that the amount would serve merely to show Sterela’s capitalization and would be returned within thirty days; Mrs. Inocencia Vives and Sanchez were the authorized signatories and held the passbook, yet Doronilla, as sole proprietor, withdrew funds several times through Assistant Manager Rufo Atienza—without presenting the passbook and in violation of bank rules—while a Current Account No. 10-0320 was opened three days later to obtain a ₱175,000 loan secured by debiting the savings account; Doronilla’s postdated checks totalling ₱212,000 issued in repayment were dishonored, prompting Vives to file Civil Case No. 444Case Digest (G.R. No. 115324)
Facts:
- Genesis of Transaction
- In 1979, private respondent Franklin Vives was asked by his neighbor Angeles Sanchez to deposit ₱200,000 into a bank account of Sterela Marketing and Services (owned by Col. Arturo Doronilla) to show sufficient capitalization for incorporation, with assurance of return within 30 days.
- On May 9, 1979, Vives issued a ₱200,000 check and authorized his wife Inocencia Vives and Sanchez to open Savings Account No. 10-1567 at Producers Bank’s Buendia branch; a passbook was issued to Mrs. Vives.
- Unauthorized Withdrawals and Postdated Checks
- Vives later discovered that Doronilla had withdrawn part of the funds, leaving only ₱90,000; Doronilla had opened Current Account No. 10-0320, obtained a ₱175,000 loan, and instructed the bank to debit the savings account to cover overdrafts; the loan’s postdated checks bounced.
- Doronilla issued postdated checks amounting to ₱212,000 (principal plus alleged interest) which were repeatedly dishonored; despite demand, Vives did not recover his deposit.
- Judicial Proceedings
- Vives filed Civil Case No. 44485 for recovery of sum of money and criminal complaints; on October 3, 1995, the RTC of Pasig (Branch 157) rendered judgment holding Doronilla, Dumagpi, and Producers Bank jointly and severally liable to pay ₱200,000 plus ₱50,000 moral damages, ₱50,000 exemplary damages, ₱40,000 attorney’s fees, and costs.
- In CA-G.R. CV No. 11791, the Court of Appeals (June 25, 1991) affirmed the RTC decision; its May 5, 1994 resolution denied petitioner’s motion for reconsideration.
- Producers Bank petitioned the Supreme Court on June 30, 1994, raising issues on the nature of the transaction, bank liability, factual findings, applicability of precedent, and award of damages.
Issues:
- Whether the transaction was a simple loan (mutuum) rather than an accommodation loan (commodatum).
- Whether bank manager Rufo Atienza connived with defendants in defrauding Vives, rendering the bank liable.
- Whether the Court of Appeals erred in adopting the RTC’s findings based on misapprehension of facts.
- Whether the precedent in Saludares v. Martinez is applicable to hold the bank liable for its employee’s acts.
- Whether Producers Bank should be jointly and severally liable for ₱200,000, moral and exemplary damages, attorney’s fees, and costs.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)