G.R. No. 236419 - Union Bank of the Philippines vs. Sy Lian Teng, Emerenciana Sylianteng, Roberto Sylianteng, Lorraine Sylianteng, Cesar Sylianteng

The case involves two groups of respondents—the Sylianteng family (composed of spouses Sy Lian Teng and Emerenciana Sylianteng, their children, and related family members) and the Tang family (composed of spouses Robert and Clarita Tang, their children, and additional relatives)—and petitioner Union Bank of the Philippines together with its branch manager, Raymond BuAag.
The dispute arose from extensive money market placements made by the respondents with Union Bank, facilitated by BuAag, who previously had an established relationship with the respondents through earlier transactions at another bank.

Starting in 1996 and continuing until 1999, the respondents invested substantial sums in money market instruments, which were evidenced by Certificates of Time Deposit, Certificates of Participation, and passbooks.
The investments were made both in Philippine Pesos and in US Dollars, with numerous rollovers and reinvestments as the instruments matured.
Detailed records specified the dates of placement, specified rates, durations, interest earned, and the respective maturity values for each investment, highlighting multiple transactions (e.g., placements on November 4, 1996; February 6, 1997; April 25, 1997; and later transactions extending to mid-1999).

The respondents alleged that after numerous rollovers, there were discrepancies in the amounts received on maturity compared to the contractually agreed amounts; specific certificates evidenced alleged deficiencies (e.g., short payments in certain Certificates of Time Deposit and Passbooks).
They further contended that BuAag, acting in his capacity as branch manager, used his apparent authority to facilitate these investments even outside the bank’s premises and later engaged in fraudulent practices—including the alleged forging of signatures and the opening of unauthorized checking accounts.
Internal bank records and subsequent audit investigations revealed that many of the money market instruments were not officially recorded in Union Bank’s treasury books, raising serious questions about the authenticity and proper handling of the placements.

It was discovered that Union Bank’s internal control system was grossly deficient. The bank failed to observe mandatory protocols for handling “accountable forms” and did not properly supervise or verify the transactions conducted by BuAag.
When discrepancies were noted by the respondents, multiple letters and requests for reconciliation were sent to Union Bank, which at times led to the initiation of criminal complaints (e.g., for Qualified Theft and Economic Sabotage) against BuAag.
Despite respondents’ efforts to clarify and retrieve their funds, Union Bank initially delivered some payments that were later disputed as being inadequate or improperly computed.

The Regional Trial Court (RTC) rendered a decision in 2013 in favor of the respondents, ordering Union Bank and BuAag to pay substantial sums for the unpaid money market placements along with moral, exemplary, and attorney’s fees.
On appeal, the Court of Appeals (CA) affirmed the RTC’s decision with modifications on the computation of interest and the deletion of certain unsubstantiated amounts, citing proper banking practices and the use of the savings deposit rate only in limited circumstances.
Union Bank then filed a petition before the Supreme Court challenging the CA’s decision on several issues related to agency, the scope of authority, and the imposition of interest and damages.

Whether an agent, such as BuAag, who exceeds his powers can still bind its principal, in this case Union Bank, under the doctrine of apparent authority.
Whether a person who personally and knowingly deals with an agent (even if the agent acts beyond his actual authority) may be deemed responsible for any resulting damage or for his own negligence.
Whether documents not specifically denied under oath (actionable documents) should be admitted and given effect by the court.
Whether a court is permitted to award relief (including damages) that is not directly supported by the evidence on record.
Whether awarding moral and exemplary damages and attorney’s fees is appropriate in the absence of a finding of malice, fraud, or bad faith on the part of the bank.