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 (A.M. No. 2005-03-SC)

Factual Background

Rafael Ma. Guerrero filed a complaint for damages against Manufacturers Hanover Trust Co. and/or Chemical Bank alleging illegally withheld taxes on interest, wrongful dishonor of a US$18,000 check for signature verification problems, and unauthorized conversion of his account. The complaint was amended. The Bank answered and asserted that the parties’ account agreement stipulated the application of New York law, which, the Bank alleged, precludes recovery except for actual damages.

Trial Court Proceedings

Manufacturers Hanover Trust Co. and/or Chemical Bank moved for partial summary judgment under Section 2, Rule 34 of the old Rules of Court to dismiss Guerrero’s claims for consequential, nominal, temperate, moral and exemplary damages and attorneys’ fees. The motion was supported by the affidavit of Alyssa Walden, a New York attorney, which was authenticated by the Philippine Consular Office in New York. The RTC denied the motion and denied reconsideration, concluding that the affidavit did not establish the absence of genuine issues of fact and did not properly prove New York law as required by the Rules on Evidence.

Court of Appeals Decision

Rafael Ma. Guerrero prevailed in the petition for certiorari filed by the Bank in the Court of Appeals. The Court of Appeals sustained the RTC’s rulings, holding that the Walden affidavit did not constitute proper proof of New York law and jurisprudence. The Court of Appeals treated the foreign law and foreign decisions the Bank sought to prove as public documents within Section 19, Rule 132, and directed that the procedure in Section 24, Rule 132 be followed to admit such proof.

Issues Presented by Petitioners

Manufacturers Hanover Trust Co. and/or Chemical Bank argued that the Court of Appeals erred in (1) holding that the Bank could not rely on the Walden affidavit to prove facts in support of its motion for summary judgment; and (2) ruling that the affidavit constituted hearsay and therefore could not prove New York law. The Bank further contended that summary judgment practice under Rule 35 (old Rules) permits reliance on affidavits and that Guerrero’s failure to file an opposing affidavit amounted to an admission of the Walden affidavit’s statements.

Parties’ Contentions

Manufacturers Hanover Trust Co. and/or Chemical Bank maintained that the Walden affidavit established as a matter of law that New York law bars recovery except for actual damages and that Guerrero offered no opposing affidavit to create a genuine issue. Rafael Ma. Guerrero opposed the motion and argued that the affidavit failed to prove foreign law under the procedural requirements of Rule 132, that the affidavit was self-serving and conclusory, and that material allegations in his complaint remained controverted and thus required trial.

Supreme Court’s Ruling

The Supreme Court denied the petition and affirmed the Court of Appeals’ Decision dated August 24, 1998 and Resolution dated December 14, 1998. The Court held that the Bank failed to prove the New York law and jurisprudence it relied upon and that the Walden affidavit, taken ex parte abroad and not presented as live testimony in open court, did not satisfy the mode of proving foreign law prescribed by Section 24, Rule 132. The Court also ruled that the Bank did not show the absence of genuine issues of fact as required for summary judgment.

Legal Basis and Reasoning

The Court restated the standard for summary judgment under Section 2, Rule 34: the moving party must demonstrate by pleadings, depositions, admissions and affidavits that no important issues of fact exist except as to damages. The Court observed that Guerrero’s complaint and the Bank’s answer presented opposing ultimate facts and defenses, which gave rise to substantial triable issues. The Court reiterated that foreign law is not a matter of judicial notice and must be alleged and proved like any other fact. Under Section 24, Rule 132, the proper proof of public records or decisions of a foreign sovereign or tribunal is by official publication or a copy attested by the custodian and, if kept abroad, accompanied by a certificate from an authorized Philippine embassy or consular official authenticated by office seal.

The Court examined precedent that permits other competent evidence of foreign law where circumstances warrant, notably Willamette Iron and Steel Works v. Muzzal and Collector of Internal Revenue v. Fisher, in which American attorneys testified in open court and quoted specific foreign statutes. The Court distinguished those authorities, noting that in those cases the evidence consisted of in-court testimony by qualified witnesses and specific verbatim statutory quotations, whereas the Walden affidavit was ex parte, did n

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