Case Digest (G.R. No. 210928)
Facts:
In Rico v. Union Bank of the Philippines, decided on February 14, 2022 under G.R. No. 210928, petitioner Rex G. Rico obtained a Union Bank Visa credit card (Account No. 4404-5305-3656) with a ₱150,000 credit limit in early 2005. Between June and November 2005, Rico discovered various unauthorized or erroneous charges on his Statements of Account, including fees for a “U-Protect Premium Plan,” an Expedia Service Fee, late‐payment interests, an annual membership fee, and a ₱30,076.79 billing that should have been only ₱347.00 for a restaurant meal. His online purchases of Tiger Airways tickets in June 2005 were disputed and later reversed, but because those disputed items remained unresolved, his minimum payment due in October 2005 rose to ₱500.00, of which he paid only ₱347.00. Consequently, Union Bank placed his account on “past due” status and dishonored his credit‐card transaction at Gourdo’s Restaurant on November 20, 2005, causing him embarrassment. Rico filed suit for damag...Case Digest (G.R. No. 210928)
Facts:
- Parties and Credit Card Account
- Petitioner Rex G. Rico was issued a Union Bank Visa credit card (Account No. 4404-5305-3656) with an initial credit limit of ₱150,000.00 and cash advance limit of ₱75,000.00 (later increased to ₱250,000.00).
- Respondent Union Bank of the Philippines managed Rico’s credit card account under a standard card membership agreement.
- Complaint and Allegations
- On January 24, 2006, Rico sued Union Bank for negligent account handling, alleging:
- Unauthorized “U-Protect Premium Plan” insurance charge.
- $20 Expedia service fee on Statement of Account (SOA) dated June 10, 2005.
- Declined Tiger Airways online transaction on June 18, 2005.
- Late payment charges and interest despite payment of May 2005 SOA on June 15, 2005.
- Annual membership fee despite waiver guarantee.
- Erroneous ₱30,076.79 charge for sushi (actual use ₱347.00) on SOA dated October 15, 2005.
- Rico also alleged that on November 20, 2005 his card was dishonored at Gourdo’s Restaurant due to supposed nonpayment, causing him embarrassment, humiliation, mental anguish, and reputation damage.
- Procedural History
- RTC, Parañaque City, Branch 195 (June 24, 2010): Found Union Bank grossly negligent; awarded Rico ₱500,000.00 moral damages, ₱200,000.00 exemplary damages, ₱300,000.00 attorney’s fees; dismissed bank’s counterclaims.
- Court of Appeals (June 28, 2013 Decision; January 21, 2014 Resolution): Affirmed RTC with modification; reduced awards to ₱30,000.00 moral damages, ₱20,000.00 exemplary damages, ₱10,000.00 attorney’s fees; denied motions for reconsideration.
- Supreme Court granted certiorari review under Rule 45, G.R. No. 210928.
Issues:
- Whether Rico is entitled to moral damages, exemplary damages, and attorney’s fees due to Union Bank’s alleged gross negligence in dishonoring his credit card transaction, which purportedly caused him embarrassment and humiliation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)