G.R. No. 47757 - Rivera vs. People

Plaintiff and Appellant: Ana Rivera, who was employed as a housekeeper by Edgar Stephenson since 1920.
Defendant and Appellee: Peoples Bank and Trust Co.
Intervenor and Appellee: Minnie Stephenson, administratrix of the intestate estate of Edgar Stephenson.

Edgar Stephenson originally opened a bank account in his name with Peoples Bank by depositing P1,000 on December 24, 1929.
On October 17, 1931, when the account balance had grown to P2,072, Stephenson executed a survivorship agreement with Ana Rivera.

The agreement stipulated that all moneys deposited by either party in the joint account were deemed to be owned by both as joint tenants.
It provided that either party could withdraw the entire deposit during their joint lives.
Upon the death of one, the balance would become the exclusive property of the survivor.

The agreement contained specific provisions authorizing the bank to receive checks and releases from either depositor to facilitate withdrawals.

After Stephenson’s death on June 8, 1939, Ana Rivera was in possession of the deposit book.
At the time of his death, the bank account had a remaining balance of P701.43.
Ana Rivera, claiming her right under the survivorship agreement, sought to withdraw the funds, but the bank refused to release the amount based on legal opinion questioning the validity of the agreement.
Minnie Stephenson intervened, contesting Rivera’s claim by asserting that the funds were the exclusive property of the deceased, thereby entitling the estate to the balance.

Ana Rivera instituted the present action against the bank to recover the remaining deposit.
The trial court held that:

Viewed during the lifetimes of the parties, the agreement functioned as a power of attorney that terminated upon Stephenson’s death.
Viewed in the context of death, it was considered a donation mortis causa, which lacked the formalities required by law (specifically under Article 620 of the Civil Code) to be valid.

The intervenor-appellee (representing the deceased’s estate) argued that the agreement was a donation mortis causa, invalid due to non-compliance with testamentary formalities.
The bank’s legal position rested on the validity of the argument that the account and the agreement were the exclusive property or power of attorney of Stephenson rather than constituting a joint tenancy arrangement.

Is the survivorship agreement entered into by Edgar Stephenson and Ana Rivera legally valid?
Does the agreement create a joint tenancy that entitles the survivor to the remaining balance upon the death of one party?

Should the agreement be characterized as merely a power of attorney that terminates upon Stephenson’s death?
Alternatively, is the agreement a donation mortis causa requiring the formalities of a testamentary disposition?

Can the certificate of deposit reflecting both names of the account holders be given full faith and credit in proving joint ownership over the funds?

Does the absence of a kinship relationship between Stephenson and Rivera, given Rivera’s role as a housekeeper, impact the validity or interpretation of their joint account and survivorship agreement?

Is the agreement covered under existing provisions of the Civil Code, particularly regarding aleatory contracts (Article 1790) and mutual obligations (Article 1255)?
Could the agreement be voided if proven to be a cloak for illicit purposes such as defrauding creditors or defeating the rights of forced heirs?