G.R. No. 248821 . October 10, 2022.
PHILIPPINE NATIONAL BANK, PETITIONER, VS. SPS. PEDRO CAGUIMBAL AND VIVIAN CAGUIMBAL, RESPONDENTS.

FACTS

Respondent Vivian Caguimbal received six checks from Baganga Plywood Corporation (Baganga Ply) as payment for delivered logs. On August 9, 2010, her daughter, Faith, inquired at PNB-Butuan Branch and was informed by officer Grace Besa that a Stop Payment Order (SPO) had been issued on all checks. Despite this knowledge, Faith’s cousin presented the checks for deposit on August 12, 2010. Officer Carlos Lim, unaware of the prior inquiry, accepted them. Five checks were returned unpaid. However, Check No. 42399 for P1,000,000.00 was not immediately returned. Respondents were told it “might be delayed.” Seeing the amount credited and intact in their account for weeks, they assumed the SPO was lifted and made subsequent deposits and withdrawals.
On September 1, 2010, PNB abruptly debited the P1,000,000.00 from the account. The bank explained it learned on August 27, 2010 that the check’s clearance was a mistake following a complaint from Baganga Ply. Respondents, having relied on the credited funds to meet obligations, were forced to borrow money. They filed a complaint for damages against PNB after demands for the return of the debited amount were refused.

ISSUE

Whether PNB is liable for damages to the respondents for the manner in which it debited the P1,000,000.00 from their account.

RULING

Yes, PNB is liable for damages. The Supreme Court affirmed the CA’s finding that while PNB had the right to debit the erroneously credited amount—as respondents, with knowledge of the SPO, were not holders in due course entitled to payment—the bank was grossly negligent in the exercise of this right. The legal logic centers on the bank’s duty to act with the highest degree of care. PNB failed in this duty by allowing the amount to remain credited for an extended period (from August 12 to September 1), leading respondents to legitimately believe the check was good and to act upon that belief. The subsequent sudden debit without prior notice violated the bank’s obligation to treat its client’s account with meticulous care.
This negligence directly caused respondents to suffer mental anguish, serious anxiety, and besmirched reputation, as they were unable to pay their own creditors, warranting an award of moral damages. Exemplary damages were also proper to set a corrective example for the banking industry. Attorney’s fees were recoverable as respondents were compelled to litigate to protect their interest. The Court emphasized that a bank’s right to correct an error does not excuse it from exercising that right in a prudent and timely manner, and its failure to do so creates liability for the damages proximately caused by its negligence.