Case Digest (G.R. No. 192413) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Rizal Commercial Banking Corporation v. Hi-Tri Development Corporation and Luz R. Bakunawa (G.R. No. 192413, June 13, 2012), petitioner Rizal Commercial Banking Corporation (RCBC) challenges the Court of Appeals’ reversal of the Makati Regional Trial Court’s (RTC) Decision in Civil Case No. 06-244, an escheat proceeding commenced by the Republic of the Philippines under Act No. 3936, as amended by P.D. 679. The Spouses Bakunawa, through their company Hi-Tri Development Corporation, paid a ₱1,019,514.29 down payment via RCBC Manager’s Check No. ER034469 to secure six sequestered parcels of land from buyer Teresita Millan in 1990. When Millan failed to complete the sale and rejected her down payment, the Spouses Bakunawa rescinded the sale but retained the undelivered check pending a separate civil action (Civil Case No. Q-91-10719). Unaware of this ongoing dispute, RCBC reported the check’s amount as an unclaimed balance to the Bureau of Treasury on January 31, 2003. The Repub Case Digest (G.R. No. 192413) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Posture
- Rizal Commercial Banking Corporation (RCBC) filed a Rule 45 petition to review the Court of Appeals (CA) decision reversing the Makati RTC’s escheat judgment.
- Republic of the Philippines, through the Office of the Solicitor General (OSG), initiated escheat proceedings (Civil Case No. 06-244) over unclaimed bank balances, including ₱1,019,514.29 held by RCBC under Manager’s Check No. ER034469.
- Underlying Transaction and Dispute
- Spouses Luz R. and Manuel Bakunawa (through Hi-Tri Development Corporation) contracted to sell sequestered land to Teresita Millan, who paid a downpayment of ₱1,019,514.29; sale was rescinded and Millan refused refund.
- Spouses Bakunawa procured from RCBC a Manager’s Check for ₱1,019,514.29 payable to Millan’s company, Rosmil Realty & Development Corp.; Millan never accepted or negotiated the check, and it remained undelivered and undebited.
- RCBC reported the balance as “unclaimed” in January 2003; Republic filed escheat complaint in December 2006, and the RTC ordered the funds forfeited to the State in May 2008.
- Respondents sought partial reconsideration and intervention, contending their ongoing Civil Case No. Q-91-10719 over the funds; the RTC denied the motion for lack of timely intervention and sufficiency of objections.
Issues:
- Jurisdictional Notice
- Whether personal service of notice to respondents is a jurisdictional requirement in escheat proceedings under Act No. 3936, as amended.
- Bank’s Notification Obligation
- Whether RCBC was obliged to notify respondents immediately before filing its sworn statement of dormant accounts with the Treasurer.
- Escheat of Allocated Funds
- Whether the ₱1,019,514.29 allocated for the Manager’s Check could properly be escheated to the Republic.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)