Case Digest (G.R. No. 211837) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The Real Bank (A Thrift Bank), Inc. v. Dalmacio Cruz Maningas, petitioner Real Bank and Metrobank are domestic banking corporations while respondent Maningas is a Filipino-British national residing in London. On August 22, 2006, Maningas drew two crossed checks totaling ₱1,152,700.00 in favor of his friend Bienvenido Rosaria, but inadvertently spelled the payee’s name as “Bienvinido Rosaria.” He mailed the checks to Rosaria’s sister in Parañaque City for deposit, yet the checks never reached her. Despite this, Metrobank debited Maningas’s account and paid the proceeds to an impostor who opened an account with Real Bank’s Bacoor branch under the misspelled name. When Maningas discovered the unauthorized withdrawal, he notified both banks, demanded reimbursement, and ultimately filed a complaint in the Regional Trial Court (RTC), Branch 61, Makati City (Civil Case No. 09-106), seeking recovery of the check amount with damages and attorney’s fees. The RTC held Real Bank liable a Case Digest (G.R. No. 211837) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- Parties
- Petitioner: The Real Bank (A Thrift Bank), Inc. (“Real Bank”), collecting bank and last indorser.
- Respondent: Dalmacio Cruz Maningas, drawer and depositor with Metrobank.
- Metropolitan Bank and Trust Company (“Metrobank”), drawee bank.
- Accounts
- Maningas maintained savings and checking accounts with Metrobank Greenhills, Eisenhower branch.
- Real Bank operated a Bacoor, Cavite branch where the impostor opened an account.
- Check Issuance and Mailing
- On August 22, 2006, while in London, Maningas drew two crossed checks (₱550,000.00 and ₱602,700.00; total ₱1,152,700.00) payable to his friend Bienvenido Rosaria, but misspelled as “BIENVINIDO ROSARIA.”
- He mailed the checks to Rosaria’s sister in Parañaque City for deposit into Rosaria’s Metrobank account.
- Unauthorized Deposit and Withdrawal
- The mailed checks never reached Rosaria; nonetheless, Metrobank debited Maningas’s account.
- A person identifying himself as “BIENVINIDO ROSARIA” opened an account at Real Bank Bacoor branch, presenting three unremarkable IDs.
- Real Bank collected the checks and forwarded them to Metrobank for clearing; after clearing, the impostor withdrew the full amount.
- Metrobank’s attempt to reverse payment on grounds of forged endorsement was rebuffed by Real Bank.
- Procedural History
- Maningas filed a complaint against both banks for recovery of the amount with damages and attorney’s fees, alleging negligence and forged indorsements.
- Real Bank answered with a counterclaim, challenging standing and invoking the fictitious-payee rule; Metrobank cross-claimed against Real Bank.
- RTC Branch 61, Makati City
- June 22, 2012 Decision: Held Real Bank solely liable to pay Maningas ₱1,152,700.00 plus 6% interest; dismissed Metrobank.
- September 13, 2012 Resolution: Denied Real Bank’s motion for reconsideration.
- Court of Appeals (CA)
- November 29, 2013 Decision and March 14, 2014 Resolution: Affirmed the RTC rulings.
- Real Bank elevated the case to the Supreme Court via petition for review on certiorari.
Issues:
- Primary Issue
- Whether Real Bank, as collecting bank and last indorser, is liable to return the amount of the checks to Maningas.
- Subsidiary Issues (raised but subsumed)
- Alleged negligence of drawer in misspelling the payee’s name and mailing method.
- Applicability of the fictitious-payee rule under the Negotiable Instruments Law.
- Alleged violation of Republic Act No. 1405 (secrecy of bank deposits) in ordering production of impostor’s bank records.
- Admissibility of additional evidence not identified in the pre-trial order.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)