Case Summary (G.R. No. 36595)
Petitioner, Respondent and Claims
Maningas, a Filipino-British national, drew two crossed checks from his Metrobank Greenhills, Eisenhower branch accounts—₱550,000 and ₱602,700—payable to his friend Bienvenido Rosaria. The checks were mailed to Rosaria’s sister in Parañaque City for deposit. Metrobank debited Maningas’s account and paid the checks to an individual posing as “Bienvinido Rosaria,” who opened an account with Real Bank in Bacoor, Cavite, deposited the checks, and withdrew the proceeds. Maningas sued both banks for recovery of ₱1,152,700 plus damages and attorney’s fees, alleging negligence, forged endorsements, and breach of implied warranties.
Key Dates
– August 22, 2006: Issuance of two crossed checks by Maningas
– September 15, 2006: Formal demand on Real Bank
– February 10, 2009: Filing of complaint in RTC Makati, Branch 61
– June 22, 2012: RTC Decision ordering Real Bank to pay
– September 13, 2012: RTC Resolution denying reconsideration
– November 29, 2013: CA Decision affirming RTC
– March 14, 2014: CA Resolution denying reconsideration
– March 16, 2022: Supreme Court Decision
Applicable Law
– 1987 Philippine Constitution (freedom from deprivation of property without due process)
– Negotiable Instruments Law (Act 2031): Sections 65–66 (endorser warranties; indorser liability), Section 9 (fictitious payee rule)
– Republic Act No. 1405 (Secrecy of Bank Deposits)
– Republic Act No. 8791 (General Banking Law of 2000): highest degree of care standard for banks
– A.M. No. 03-1-09-SC (pre-trial guidelines)
RTC Findings and Ruling
The Regional Trial Court held:
• The intended payee was Rosaria; the misspelling “Bienvinido” was inadvertent.
• Metrobank (drawee) was not negligent: it paid upon genuine presentment and relied on Real Bank’s guarantee.
• Real Bank (collecting bank and last indorser) breached its warranty under Section 66 NIL by failing to ascertain the genuineness of prior endorsements, inadequately vetting identification documents, and ignoring notice of suspected forgery.
• The fictitious-payee rule did not apply because Rosaria exists and was the intended payee.
• Real Bank was solely liable to Maningas for ₱1,152,700 plus 6% interest per annum from filing until full payment. Metrobank’s cross-claim against Real Bank was dismissed.
CA Ruling
The Court of Appeals affirmed:
• RTC properly admitted additional documentary and testimonial evidence—Real Bank waived objections by inaction.
• Maningas exercised due diligence; he was not grossly negligent in misspelling or mailing the checks.
• Real Bank failed the high standard of care under the General Banking Law and breached its guarantee.
• The fictitious-payee rule was inapplicable.
• No violation of RA 1405 occurred, since the impostor’s account was directly at issue in the litigation.
Issue Before the Supreme Court
Whether Real Bank is liable to return the amount of the checks to Maningas, applying the 1987 Constitution and relevant banking and negotiable instruments law.
Supreme Court Analysis and Holding
Banks’ Sequence of Liability
– Drawee bank (Metrobank) is under strict liability to charge a drawer’s account only for properly payable checks and may seek reimbursement from the collecting bank upon unauthorized payment.
– Collecting bank (Real Bank), as general endorser, warrants under Section 66 NIL the genuineness of prior endorsements and is liable for breaches of those warranties.Metrobank’s Non-Liability
– Metrobank’s acquittal became final due to the absence of appeal. It strictly complied with its duty by paying the named payee, despite a typographical error.Real Bank’s Liability
– Real Bank’s guarantees were false: the impostor lacked title and used forged endorsements.
– The bank was negligent in document verification and inaction upon notice of forgery.
– Maningas exercised due diligence; his inadvertent misspelling does not preclude the defense of forgery or shift liability.Direct Recovery and Simplification
– Direct recourse against the collecting bank is permissible where drawee bank liability is final or strictly compliant with its duties.Fictitious-Pay
Case Syllabus (G.R. No. 36595)
Procedural History
- Petition for review on certiorari filed by Real Bank in G.R. No. 211837 contesting:
- Court of Appeals Decision, November 29, 2013, and Resolution, March 14, 2014, in CA-AG.R. CV No. 99817
- These CA rulings affirmed the Regional Trial Court (RTC), Branch 61, Makati City Decision, June 22, 2012, and Resolution, September 13, 2012, in Civil Case No. 09-106
- RTC denied Real Bank’s motion for reconsideration; CA likewise denied its motion for reconsideration
- Petitioners elevated the case to the Supreme Court, raising errors in evidence admission, findings on negligence, applicability of the fictitious-payee rule, and violation of bank-secrecy law
Factual Antecedents
- Dalmacio Cruz Maningas, a Filipino-British national residing in London, held savings and checking accounts with Metrobank, Greenhills Eisenhower branch
- On August 22, 2006, while in London, Maningas issued two crossed checks totaling ₱1,152,700.00 payable to his friend Bienvenido Rosaria for payment of a land parcel
- Checks bore the misspelled payee name “BIENVINIDO ROSARIA”; Maningas mailed them to Rosaria’s sister in Parañaque City for deposit
- Maningas discovered his Metrobank account debited though checks were never received; Metrobank informed him that Real Bank paid the checks to a person representing himself as BIENVINIDO ROSARIA
- Real Bank’s Bacoor, Cavite branch opened an account for the impostor who presented valid-looking IDs, deposited the checks, and withdrew the full amount after clearing
- Maningas alerted Metrobank and Real Bank of forged endorsements and sent a formal demand; both banks ignored or denied responsibility, prompting his complaint for recovery with damages
Parties’ Contentions
- Maningas:
- Metrobank breached its duty by paying to an unauthorized endorser without notifying the drawer
- Real Bank, as collecting bank and last indorser, violated implied warranties of genuineness of checks and validity of prior endorsements
- Real Bank:
- Maningas lacked standing; Rosaria was the real party in interest
- Bank complied with all rules: IDs were untampered, checks cleared before withdrawal
- Fictitious-payee rule applied, converting checks to bearer instruments and precluding challenge to forgery
- Any loss resulted from Maningas’s own negligence in misspelling payee name and mailing method
- Metrobank:
- Liability, if any, rests with Real Bank under indemnity principle
- As drawee, it merely followed drawer’s instructions and relied on Real Bank’s guarantee
Ruling of the Regional Trial Court
- Found Maningas intended to pay Rosaria and that the misspelling was inadvertent
- Held Real Bank negligent as colle