Title
Spouses Carbonell vs. Metropolitan Bank and Trust Co.
Case
G.R. No. 178467
Decision Date
Apr 26, 2017
Spouses Carbonell sued Metrobank after counterfeit US$100 bills from their account caused public humiliation in Thailand. Court ruled no gross negligence or bad faith by bank, denying damages.

Case Digest (G.R. No. 178467)
Expanded Legal Reasoning Model

Facts:

  • Withdrawal and initial discovery
    • Petitioners Cristino and Edna Carbonell withdrew US$1,000 in US$100 bills from their dollar account at Metrobank’s Pateros branch prior to their trip to Bangkok, Thailand.
    • In Bangkok, they attempted to exchange five US$100 bills but only four were accepted; the fifth was rejected as “no good” and later confiscated by a Thai bank teller as counterfeit.
  • Subsequent transactions and humiliation
    • The petitioners used the remaining four US$100 bills to purchase jewelry, only to be confronted by the shop owner the next day when those bills proved counterfeit.
    • The shop owner publicly accused them of cheating, causing emotional shock, mental anguish, public ridicule, humiliation, insults, and embarrassment.
  • Post-trip correspondence and demand
    • Upon returning to the Philippines, the petitioners confronted Metrobank’s branch manager, who maintained the genuineness of the bills, citing issuance from the head office.
    • The petitioners’ counsel submitted the four bills to the Bangko Sentral ng Pilipinas (BSP), which certified them as “near perfect genuine notes.”
    • The petitioners demanded P10 million in moral and exemplary damages, giving Metrobank five days to comply or face litigation.
  • Pre-litigation negotiations and relief
    • Metrobank’s counsel expressed sympathy but disclaimed absolute guarantee on note authenticity, asserting due diligence in handling foreign currency and supervising employees.
    • In two meetings, Metrobank offered to reinstate US$500 and provide a round-trip all-expense-paid ticket to Hong Kong; the petitioners rejected these offers.
  • Procedural history
    • The petitioners filed Civil Case No. 65725 in the RTC, alleging damages for emotional and reputational harm.
    • On May 22, 1998, the RTC dismissed the complaint for lack of merit and awarded Metrobank P20,000 as attorney’s fees on its counterclaim.
    • On December 7, 2006, the CA affirmed the dismissal but deleted the award of attorney’s fees.
    • The petitioners elevated the case to the Supreme Court via petition for review on certiorari.

Issues:

  • Whether Metrobank failed to exercise the high degree of diligence required of banks in handling foreign currency, rendering it liable for gross negligence, misrepresentation, and bad faith.
  • Whether the absence of bad faith or fraud precludes the award of moral and exemplary damages against the bank in a breach‐of‐contract action.
  • Whether the petitioners’ public humiliation and emotional harm abroad constitute a legal injury compensable under Philippine law (i.e., whether damnum absque injuria applies).

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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