Case Summary (G.R. No. 173259)
Factual Antecedents
FFCCI, represented by its President Felipe Cruz and Secretary-Treasurer Angelita A. Cruz, held a savings account with PNB and authorized transactions on that account. While both signatories were temporarily out of the country, unauthorized applications for manager's checks totaling ₱13,210,500.31 were made against the account. Upon discovering these discrepancies upon Angelita's return, FFCCI requested PNB to rectify these unauthorized transactions, but PNB refused, prompting FFCCI to file a lawsuit for damages against PNB.
Regional Trial Court's Ruling
The Regional Trial Court determined that both parties exhibited negligence. FFCCI was deemed negligent for allowing their accountant, Aurea Caparas, to implement decisions regarding account transactions without strict oversight, effectively waiving the requirement for dual signatures. Conversely, PNB was also found negligent for failing to properly verify the large withdrawals. The trial court ruled that PNB bore the greater responsibility for the loss and ordered the bank to compensate FFCCI for the full amount debited.
Court of Appeals' Ruling
The Court of Appeals affirmed the trial court's decision but adjusted the allocation of damages. It held that PNB's failure to verify the genuineness of the signatures during the check processing constituted negligence, since the absence of a verifier's signature suggested a breakdown of the verification process. Nonetheless, it identified FFCCI’s contributory negligence in not promptly reviewing account statements, resulting in a modification of the trial court's ruling to a 60-40 liability split favoring PNB.
Petition for Review and Issues Raised
Both parties sought further review by the Supreme Court. The main issue was whether the Court of Appeals erred in attributing negligence to PNB. FFCCI contended that PNB’s negligence justified a full reimbursement of their losses, while PNB argued that its verification procedures mitigated its liability and FFCCI’s lack of vigilance exacerbated the situation.
Supreme Court's Ruling
The Supreme Court upheld the Court of Appeals' findings regarding PNB's negligence while also recognizing FFCCI's contributory negligence. It confirmed the 60-40 liability distribution between PNB and FFCCI, stating that PNB's failure to detect the forgeri
...continue readingCase Syllabus (G.R. No. 173259)
Overview of the Case
- The case involves a petition for review on certiorari by the Philippine National Bank (PNB) against F.F. Cruz and Co., Inc. (FFCCI).
- The Supreme Court is reviewing the Court of Appeals' decision which modified the ruling of the Regional Trial Court concerning unauthorized debits from FFCCI's bank accounts.
- The central legal question pertains to the liability of the bank and the issue of contributory negligence by the depositor.
Factual Antecedents
- FFCCI opened a combo account and a dollar savings account with PNB, with Felipe Cruz and Angelita A. Cruz as authorized signatories.
- Both signatories traveled to the United States, during which time applications for cashier's and manager's checks were processed and approved by PNB.
- Upon Angelita's return, she discovered unauthorized withdrawals totaling P13,210,500.31, which led to FFCCI filing a lawsuit against PNB, asserting these transactions were fraudulent.
- PNB contended that it followed due diligence in processing the checks and that FFCCI's delay in reviewing the account statements contributed to their losses.
Regional Trial Court's Ruling
- The trial court found FFCCI negligent for granting Caparas, its accountant, excessive authority, facilitating the fraudulent transactions.
- The court acknowledged PNB's negligence for not verifying the legitimacy