G.R. No. 88866 ; February 18, 1991
METROPOLITAN BANK & TRUST COMPANY, petitioner, vs. COURT OF APPEALS, GOLDEN SAVINGS & LOAN ASSOCIATION, INC., LUCIA CASTILLO, MAGNO CASTILLO and GLORIA CASTILLO, respondents.

FACTS

Eduardo Gomez deposited 38 Philippine Fish Marketing Authority treasury warrants, totaling P1,755,228.37, with respondent Golden Savings & Loan Association. Golden Savings, through its cashier Gloria Castillo, endorsed these warrants for deposit into its savings account with petitioner Metrobank’s Calapan branch for clearing. Metrobank forwarded the warrants to the Bureau of Treasury for special clearing. After repeated inquiries from Golden Savings about the clearance status and as an accommodation to a valued client, Metrobank permitted Golden Savings to withdraw P968,000 from the uncleared proceeds between July 9 and 16, 1979. Relying on this, Golden Savings subsequently allowed Gomez to withdraw P1,167,500 from his account.
On July 21, 1979, Metrobank informed Golden Savings that 32 warrants had been dishonored on July 19 and demanded a refund of the withdrawn amount. Golden Savings refused. Metrobank sued for recovery. The trial court, later affirmed by the Court of Appeals, dismissed Metrobank’s complaint, ordered the reinstatement of the debited amount to Golden Savings’ account, and awarded attorney’s fees.

ISSUE

Whether Metrobank was negligent in allowing withdrawals against un-cleared treasury warrants, thereby bearing the loss from their subsequent dishonor.

RULING

Yes, Metrobank was negligent and must bear the loss. The Supreme Court affirmed the appellate court’s decision with modification. The core legal logic rests on the bank’s duty of care as a collecting agent. Golden Savings, lacking clearing facilities, relied entirely on Metrobank to validate the warrants. By permitting withdrawals against un-cleared items, Metrobank created the clear impression that the warrants were good and had been cleared. This assurance directly induced Golden Savings to allow Gomez’s withdrawals. Metrobank’s accommodation, despite the lack of official clearance, constituted negligence.
The Court rejected Metrobank’s defenses. The deposit slip’s charge-back provisions do not absolve the bank from its primary negligence in misleading its client. The treasury warrants were non-negotiable instruments; thus, the Negotiable Instruments Law and doctrines on forgery liability (like in Jai Alai Corp. v. BPI) are inapplicable. Golden Savings’ endorsement was merely for deposit, not a guarantee of genuineness—a guarantee Metrobank itself provided by stamping the warrants. The loss allocation must reflect this negligence. Therefore, the amount Gomez successfully withdrew (P1,167,500) is Metrobank’s loss. However, the remaining balance of the dishonored warrants (P586,589) should be debited from Golden Savings’ account, as it would be unjustly enriched if credited with funds from warrants it knew were dishonored. The decision was modified to effect this apportionment.