Case Summary (G.R. No. 132390)
Factual Background
FMIC, represented by Executive Vice President Antonio Ong, deposited a METROBANK check worth P100 million with BPI Family Bank. This deposit was part of a verbal agreement wherein BPI Family Bank, through Branch Manager Jaime Sebastian, guaranteed an interest rate of 17% per annum, with the condition that FMIC would maintain the deposit for one year and receive the interest in advance. After paying the interest, an unauthorized transfer of P80 million was made to a third-party account, prompting FMIC to initiate legal action against BPI Family Bank for recovering its deposited funds.
Initial Court Proceedings
The Regional Trial Court rendered a decision that ordered BPI Family Bank to pay FMIC the amount of P80 million plus legal interest, reflecting the amount owed after accounting for the interest that had already been paid. Both parties appealed this decision, leading to a modified ruling by the Court of Appeals, which ordered BPI Family Bank to pay a revised amount of P65,332,321.99 plus interest.
Assignments of Error
BPI Family Bank alleged multiple errors in the Court of Appeals' ruling. It contended that the agreement regarding the deposit was invalid, characterized it incorrectly as a time deposit rather than a demand deposit, and asserted that the Branch Manager acted without proper authority. Furthermore, it maintained that the Court of Appeals failed to acknowledge FMIC's negligence leading to the unauthorized transfer and that the awarded amount exceeded FMIC's original claims.
Nature of the Deposit
The Supreme Court clarified that despite BPI's claims, the evidence demonstrated that the parties intended for the deposit to be treated as a time deposit, with restrictions on withdrawal for one year. The Court emphasized that FMIC could only withdraw funds in light of unauthorized actions taken by BPI Bank, thus not converting the arrangement into a demand deposit.
Regulatory Context
BPI Family Bank further argued that Central Bank regulations prohibited the earning of interest on demand deposits. However, the Court pointed out that existing regulations do allow for interest on demand deposits and reaffirmed that the classification of the account should not deprive FMIC of its right to receive interest.
Authority of the Branch Manager
The Court addressed the issue of authority concerning Branch Manager Jaime Sebastian, establishing that a corporation is bound by the actions of its authorized agents when they are acting within the scope of apparent authority. The ruling reiterated that BPI Family Bank, by allowing its representative to engage in the investment transaction, cannot now refute the responsibility arising from that transaction.
Award of Interest
The Court ruled that FMIC was entitled to the stipulated interest amount, as established in their agreement. It emphasized that the interest obligation is valid even if FMIC's original complaint lacked specific req
...continue readingCase Syllabus (G.R. No. 132390)
Case Overview
- This case involves a petition for review on certiorari filed by BPI Family Savings Bank, Inc. (Petitioner) against First Metro Investment Corporation (Respondent) regarding a dispute over a deposit agreement and the subsequent transfer of funds.
- The petition arises from the Decision dated July 4, 1997, and Resolution dated January 28, 1998, of the Court of Appeals in CA-G.R. CV No. 44986, which affirmed the trial court's ruling.
Parties Involved
- Petitioner: BPI Family Savings Bank, Inc., a banking corporation organized under Philippine laws.
- Respondent: First Metro Investment Corporation (FMIC), an investment house organized under Philippine laws.
Factual Background
- On August 25, 1989, FMIC opened a current account with BPI Family Bank and deposited a check of P100 million.
- The deposit was made upon the request of Ador de Asis, a close acquaintance of the branch manager, Jaime Sebastian, who guaranteed an interest rate of 17% per annum.
- FMIC agreed to keep the deposit for one year in exchange for this interest, which was to be paid in advance.
- BPI FB subsequently paid FMIC the agreed interest of P14,667,687.01 upon the check's clearance.
- On August 29, 1989, BPI FB transferred P80 million from FMIC's account to Tevesteco Arrastre and Stevedoring, Inc. without FMIC's authorization, which FMIC claimed was due to falsified signatures.
- FMIC issued a check for P86,057,646.72 for withdrawal, which