G.R. No. 223694 - Banta vs. Equitable Bank, Inc.

Court: Supreme Court of the Philippines
Date: February 10, 2021
Petitioner: Remedios T. Banta
Respondents: Equitable Bank, Inc. (now BDO Unibank, Inc.), Antonio Banta, Armando Banta, Sonia Banta, Erlinda Tan, and the Register of Deeds of Malabon City
Legal Basis: Petition for review under Rule 45 of the Rules of Court

The petitioner, Remedios T. Banta, and Antonio Banta were married in 1975 but separated in 1991.
In 1997, Remedios discovered that Antonio had forged her signature to secure loans from Equitable Bank, using the properties registered under their names as collateral.
Legal actions ensued to annul the mortgage agreements based on the forgery of her signature.

Outcome: The Regional Trial Court (RTC) declared the "Amendment to Real Estate Mortgage" null and void due to the forged signature, ordering Antonio Banta and the Bank to cancel the mortgage agreement and pay attorney’s fees.
Key Findings:
- The RTC found no cause of action against Armando, Sonia, and Erlinda as the properties were not under Remedios' name.
- The Bank was negligent for failing to verify the authenticity of Remedios' signature.

The Court of Appeals (CA) awarded moral and exemplary damages to Remedios but released the Bank from joint liability, stating it lacked bad faith or conspiracy with Antonio.
Key Adjustments:
- Remedios was granted P300,000 in moral damages, P100,000 in exemplary damages, and P100,000 in attorney’s fees.
- The Bank was not held jointly liable due to lack of evidence of bad faith.

Central Issue: Whether the Bank should be held jointly and severally liable for damages and attorney’s fees with Antonio.
Court’s Findings:
- The Bank's negligence in verifying the authenticity of the signature constituted a lack of due diligence.
- The decision emphasized banks' obligation to exercise extraordinary diligence in transactions.

Negligence: The Bank failed to verify signed documents adequately, making it liable for damages.
Moral and Exemplary Damages: Awarded to compensate Remedios for psychological trauma and to set an example of care required from banks.
Joint and Several Liability: The Bank is held jointly liable with Antonio for the damages due to its negligence.

Liabilities Assigned:
- Equitable Bank (now BDO Unibank, Inc.) and Antonio Banta are jointly liable to pay:
  - P100,000 as moral damages
  - P100,000 as exemplary damages
  - P100,000 for attorney’s fees
The Court affirmed the RTC's ruling on the properties not owned by Remedios.

Civil Code Articles: Relevant provisions include Article 2220 (moral damages) and Article 2229 (exemplary damages).
Legal Precedents: Cited cases emphasize banks’ responsibilities and liabilities in acts of negligence.

The Supreme Court reaffirmed the necessity for banks to exercise extraordinary diligence, especially regarding the verification of signatures on mortgage documents.
The ruling highlighted the si