Case Summary (G.R. No. 141011)
Antecedent Facts
In February 1984, Villanueva opened a savings account and a current account at the bank. On May 21, 1986, he deposited funds into his savings account and requested a new checkbook due to a lack of blank checks. He was assisted by a customer service representative who assured him she would provide his current account number. The representative erroneously wrote down another customer’s account number sharing Villanueva’s name.
Issuance and Dishonor of Check
Villanueva received the checkbook on June 17, 1986, and issued a check for P50,000 to Kingly Commodities Traders on June 19, 1986. He deposited additional cash to cover the check amount. However, on June 23, the check was dishonored due to insufficient funds and a signature discrepancy. Villanueva communicated with the bank and was assured the check would be honored after the situation was clarified.
Repeated Dishonor and Bank's Response
Despite reassurances from the bank, the check was dishonored again on June 26, which Villanueva investigated by visiting the bank. The bank officials informed him that the issue stemmed from the fact that the erroneous account number provided belonged to another depositor with a similar name. The bank issued a manager's check for P50,000 to Kingly Commodities as a remedy.
Demand for Indemnification
Subsequently, Villanueva demanded indemnification from the bank, asserting that the dishonor of the check caused him significant financial losses and humiliation. He originally sought P70,000 for actual damages and P2 million for moral damages. The bank responded, acknowledging the oversight but attributing the dishonor to Villanueva's failure to provide his correct account number.
Initiation of Legal Action
Frustrated with the bank's response, Villanueva filed a complaint for damages on August 27, 1986, claiming breach of contract and quasi-delict, due to the bank’s negligence in processing his checkbook requisition.
Trial Court's Findings
The trial court dismissed Villanueva's complaint in July 1992, attributing his alleged losses to his own negligence. The court found his failure to verify his account details and provide necessary information as the proximate cause of his damages. The court acknowledged the bank's negligence but deemed it merely contributory.
Appeal to Court of Appeals
Villanueva appealed the trial court's decision, maintaining that the bank’s gross negligence in supplying the wrong account number was the cause of his losses. The Court of Appeals favored Villanueva, determining that the bank had assumed responsibility for errors in the requisition process and ordered moral damages of P100,000 and attorney's fees.
Subsequent Appeals and Supreme Court Ruling
Both parties subsequently filed for review, with the bank contesting the Court of Appeals’ findings and Villanueva challenging the denial of his claimed actual losses. The Supreme Court asserted that Villanuev
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Background of the Case
- The case involves two consolidated petitions: one from Citytrust Banking Corporation (now Bank of the Philippine Islands) and the other from Isagani C. Villanueva.
- The core issue is whether the repeated dishonor of a check, which was drawn against a well-funded account but bore an incorrect account number due to a mistake by the bank, warrants compensatory and moral damages as well as attorney's fees for the drawer.
Factual Antecedents
- In February 1984, Isagani C. Villanueva opened a savings and a current account with Citytrust Banking Corporation.
- On May 21, 1986, Villanueva deposited money into his savings account and subsequently requested a new checkbook from the bank.
- Due to not recalling his current account number, a bank representative erroneously provided him with the account number of another depositor with a similar name.
- Villanueva received his checkbook on June 17, 1986, and issued Check No. 396701 for P50,000 to Kingly Commodities Traders and Multi Resources, Inc.
Events Leading to the Dishonor of the Check
- Two days after issuing the check, Villanueva was informed that the check had been dishonored due to insufficient funds and a signature discrepancy.
- Villanueva contacted the bank manager, Maritess Gamboa, who assured him that the check would be honored after further verification.
- On June 26, 1986, the check was dishonored again, this time citing a stop-payment order, which Villanueva claimed he never issued.
- Upon investigation, it was revealed that the dishonor was due to the account number bein