Title
Manufacturers Hanover Trust Co. vs. Guerrero
Case
G.R. No. 136804
Decision Date
Feb 19, 2003
A dispute over damages involving a bank's alleged unauthorized actions, governed by New York law, led to a Supreme Court ruling affirming the need for proper proof of foreign law and rejecting summary judgment due to unresolved factual issues.

Case Summary (G.R. No. 136804)

Petition Before the Supreme Court

The Bank sought review under Rule 45 of the Rules of Court of the Court of Appeals’ August 24, 1998 Decision and December 14, 1998 Resolution affirming the trial court’s denial of its motion for partial summary judgment.

Antecedents and Trial Court Proceedings

On May 17, 1994, Guerrero sued the Bank for damages allegedly arising from:

  1. Illegally withheld taxes on interest from his checking account;
  2. A returned US$18,000 check due to signature verification;
  3. Unauthorized conversion of his account.
    The Bank answered on September 1, 1995, invoking a stipulation that New York law governs and bars all claims except actual damages. It moved for partial summary judgment to dismiss claims for consequential, nominal, temperate, moral, exemplary damages, and attorney’s fees. Guerrero opposed. The Bank’s New York attorney, Alyssa Walden, submitted an affidavit attesting to New York law, which was authenticated by the Philippine Consular Office in New York. The RTC denied the motion (March 6, 1996) and the motion for reconsideration (July 17, 1996).

Court of Appeals’ Decision

The Court of Appeals dismissed the Bank’s certiorari petition, ruling that:
• The Walden affidavit does not constitute proper proof of New York law and jurisprudence.
• Foreign law must be proved as public documents under Sections 19 and 24, Rule 132 of the Rules on Evidence (by official publication or certified copy with proper embassy or consular certification).
• Rule 34’s supporting affidavit requirement does not dispense with the formal procedure for proving foreign law.

Issues on Appeal

The Bank asserted that the Court of Appeals erred by holding that:

  1. Its evidentiary proof by affidavit is inadmissible for summary judgment purposes;
  2. The Walden affidavit is hearsay and cannot establish New York law;
  3. Guerrero’s failure to file an opposing affidavit precludes any genuine issue of fact.

Supreme Court Ruling on Summary Judgment Standards

Under Section 2, Rule 34 of the old Rules of Court, summary judgment requires a showing—through pleadings, depositions, admissions, and affidavits—that no genuine issue of material fact exists except on damages. A genuine issue is one that demands evidence rather than being contrived. Here, Guerrero’s complaint and the Bank’s answer contain conflicting allegations on the applicability and effect of New York law, establishing triable issues.

Proof of Foreign Law

Foreign law is treated as a fact and must be alleged and proven, as it is not subject to judicial notice. Section 24, Rule 132 mandates proof by official publication or certified copy, accompanied by a custody certificate from authorized Philippine consular or embassy officials. Although exceptions permit other competent evidence (e.g., attorney testimony in open court), such evidence must be presented at trial, not through an ex parte affidavit.

Sufficiency of the Walden Affidavit

The Walden affidavit presents conclusions and opinions about New York law without citing official statutes or certified decisions. Its references to U.S. court cases and treatises are not accompanied by certified copies under Rule 132

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