Case Summary (G.R. No. 219709)
Petitioner and Respondents
Petitioner: Metropolitan Bank & Trust Company
Respondents: Golden Savings & Loan Association, Inc.; Lucia Castillo; Magno Castillo; Gloria Castillo; Court of Appeals (as nominal respondent on appeal)
Applicable Law
– 1987 Philippine Constitution (decision date February 18, 1991)
– Civil Code, Article 1909 (liability of agent for negligence)
– Negotiable Instruments Law, Sections 1 and 3 (definition and unconditional nature of negotiable instruments)
– Jurisprudence on agency negligence and non-negotiable treasury warrants
Chronology of Facts
- January 1979: Gomez opens an account with Golden Savings and deposits 38 treasury warrants worth P1,755,228.37, drawn by the Philippine Fish Marketing Authority.
- June 25–July 16, 1979: Gloria Castillo indorses the warrants and deposits them to Golden Savings’ account in Metrobank Calapan; Metrobank forwards them for special clearing.
- July 9, 13, and 16, 1979: Metrobank allows Golden Savings to withdraw P508,000; P310,000; and P150,000 respectively (total P968,000), despite warrants not yet cleared.
- By July 16, 1979: Gomez withdraws P1,167,500 from his Golden Savings account.
- July 19, 1979: Bureau of Treasury dishonors 32 warrants.
- July 21, 1979: Metrobank demands refund of P1,754,089; demand rejected. Metrobank sues Golden Savings in the RTC of Mindoro.
Procedural History
– RTC Decision (Nov. 4, 1986): Dismissed Metrobank’s complaint; ordered reversal of debits and payment of attorney’s fees to Golden Savings and the Castillos.
– Court of Appeals: Affirmed the RTC decision.
– This petition: Metrobank appeals to the Supreme Court raising contractual charge-back rights, allocation of loss, and negotiability of warrants.
Issues Presented
- Whether Metrobank’s printed deposit-slip conditions shield it from liability and permit charge-back of amounts credited on dishonored warrants.
- Which party should bear the loss from dishonored treasury warrants.
- Whether the treasury warrants qualify as negotiable instruments.
- Whether Golden Savings was negligent in accepting and paying out cleared funds.
Supreme Court’s Analysis
– Agency Negligence (Art. 1909): A collecting bank is liable for negligence. Metrobank’s implied assurance of clearance, as evidenced by permitting three withdrawals, misled Golden Savings into paying Gomez.
– Deposit-Slip Conditions: Even if contractual, Metrobank cannot invoke unconscionable disclaimers to avoid responsibility arising from its own negligence in misrepresenting clearance.
– Due Care by Golden Savings: It deposited warrants for clearance and refrained from paying Gomez until Metrobank’s go-ahead. No negligence in identity or genuineness checks.
– Proof of Forgery: No clear, positive, and convincing evidence of forgery on the warrants; lower courts’ factual finding of non-forgery stands.
– Nature of Treasury Warrants: Clearly stamped “non-negotiable” an
Case Syllabus (G.R. No. 219709)
Facts
- Metropolitan Bank & Trust Company (Metrobank) operates branches nationwide; Golden Savings & Loan Association, Inc. (Golden Savings) operates in Calapan, Mindoro, with Lucia Castillo, Magno Castillo and Gloria Castillo as officers.
- In January 1979, Eduardo Gomez opened an account with Golden Savings and, over two months, deposited 38 treasury warrants totaling ₱1,755,228.37 drawn by the Philippine Fish Marketing Authority, some payable directly to him and others indorsed by previous payees.
- Between June 25 and July 16, 1979, Gloria Castillo indorsed and deposited these warrants to Golden Savings’ Savings Account No. 2498 at Metrobank–Calapan. Metrobank forwarded them for special clearing to the Bureau of Treasury.
- For more than two weeks, Metrobank deferred the release of funds pending actual clearance. Repeated inquiries by Gloria Castillo were met with assurances that Golden Savings could withdraw as an accommodation to a valued client.
- Golden Savings withdrew ₱508,000.00 on July 9, ₱310,000.00 on July 13, and ₱150,000.00 on July 16, 1979—totaling ₱968,000.00. Gomez then withdrew ₱1,167,500.00 from his own account.
- On July 21, 1979, 32 of the warrants were dishonored by the Bureau of Treasury, creating a deficit. Metrobank demanded refund from Golden Savings, which refused. Metrobank sued in the Regional Trial Court (RTC) of Mindoro.
Procedural History
- The RTC rendered judgment in favor of Golden Savings. Both parties moved for reconsideration and appeal: Golden Savings filed for reconsideration; Metrobank appealed.
- On November 4, 1986, the RTC modified its decision to dismiss Metrobank’s complaint, dissolve attachments, restore Savings Account No. 2498 to its pre-debit balance (including ₱812,033.37), and award attorney’s fees (₱200,000 to Golden Savings; ₱100,000 to the Castillos).
- Golden Savings appealed to th