Case Digest (G.R. No. 225538) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Yon Mitori International Industries, a single proprietorship owned and operated by Rodriguez Ong Tan (Tan), Tan maintained Current Account No. 027-03-000181-8 with Union Bank of the Philippines (Union Bank) at its Commonwealth, Quezon City branch. On November 12, 2007, Tan deposited a Bank of the Philippine Islands (BPI) Check No. 0180724 for ₱420,000.00 drawn on Angli Lumber & Hardware, Inc.’s closed account. Union Bank’s system inadvertently credited the full ₱420,000.00—together with a prior balance of ₱93,700.60 and a separate encashment of ₱1,000.00—bringing Tan’s balance to ₱514,700.60. The same day, Tan withdrew ₱480,000.00. Later, BPI returned the check for “Account Closed,” prompting Union Bank on November 20, 2007 to demand reimbursement, which Tan refused. Union Bank debited the remaining ₱34,700.60 from his account and filed a Complaint for Sum of Money before the Regional Trial Court (RTC) of Pasig City for the recovery of ₱385,299.40 plus legal interest, attorne Case Digest (G.R. No. 225538) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Transaction
- Yon Mitori International Industries, a sole proprietorship owned and operated by Rodriguez Ong Tan, maintained Current Account No. 027-03-000181-8 with Union Bank of the Philippines (Union Bank).
- On November 12, 2007, Tan deposited a P420,000.00 BPI check drawn by Angli Lumber & Hardware, Inc., despite having five prior BPI checks from the same drawer dishonored for “Account Closed.”
- Erroneous Credit and Withdrawal
- Due to a technical error, Union Bank credited P420,000.00, raising Tan’s balance from P93,700.60 to P513,700.60.
- On November 14, 2007, Tan withdrew P480,000.00. Later that day, the BPI check was returned unpaid because the drawee account was closed.
- Demand, Debit, and Suit
- Union Bank immediately demanded return of P420,000.00 on November 20, 2007; Tan refused.
- The bank debited Tan’s remaining balance of P34,700.60 and filed a Complaint for recovery of P385,299.40 plus damages, attorney’s fees, and costs before the RTC of Pasig City.
- Proceedings Below
- RTC (Feb. 24, 2014): Held that solutio indebiti applied; ordered Tan to pay P385,299.40, 12% interest from June 13, 2008, P100,000 attorney’s fees, and P14,954.20 costs. Denied reconsideration on May 19, 2014.
- CA (Feb. 3, 2016): Affirmed with modification—deleted attorney’s fees and costs, reduced interest rate to 6% per annum. Denied motion for reconsideration on July 5, 2016.
Issues:
- Whether the Court of Appeals erred in affirming the RTC’s decision directing Rodriguez Ong Tan (Yon Mitori) to return the value of the dishonored BPI check with legal interest.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)