GR 179096; (February, 2013) (Digest)
G.R. No. 179096 ; February 06, 2013
JOSEPH GOYANKO, JR., as administrator of the Estate of Joseph Goyanko, Sr., Petitioner, vs. UNITED COCONUT PLANTERS BANK, MANGO AVENUE BRANCH, Respondent.
FACTS
The late Joseph Goyanko, Sr. invested P2,000,000.00 with Philippine Asia Lending Investors, Inc. (PALII). Due to conflicting claims from his legitimate and illegitimate families over the investment proceeds, PALII deposited the amount with United Coconut Planters Bank (UCPB) under the account name “Phil Asia: ITF (In Trust For) The Heirs of Joseph Goyanko, Sr.” On December 11, 1997, UCPB allowed PALII to withdraw P1,500,000.00 from this account. Joseph Goyanko, Jr., as administrator of the estate, demanded that UCPB restore the withdrawn amount. Upon UCPB’s refusal, a complaint for sum of money was filed.
The Regional Trial Court dismissed the complaint, ruling that the words “ITF HEIRS” were insufficient to charge UCPB with knowledge of a trust relationship, and that the deposit contract was solely between PALII and UCPB. The Court of Appeals affirmed this decision, holding that no express trust was created as there was no clear intention to establish one, and thus UCPB was not liable for the withdrawal.
ISSUE
Whether UCPB should be held liable for the amount withdrawn on the ground that a trust agreement existed between PALII and UCPB in favor of the heirs.
RULING
The Supreme Court ruled in the negative, affirming the lower courts’ decisions. The Court held that no express trust was created. The essential elements of an express trust—a competent trustor and trustee, a clear intent to create a trust, a definite trust res, and a valid trust purpose—were not established. The mere designation “ITF” on the account was insufficient to prove such intent, especially absent a trust agreement between PALII and UCPB. The contract remained an ordinary savings deposit, creating a simple debtor-creditor relationship between PALII (as the depositor-account holder) and UCPB.
Consequently, UCPB’s obligation was to return the deposit to the account holder, PALII, upon its demand. The bank was not negligent in allowing the withdrawal by the authorized signatory of the account. The petitioner’s failure to substantiate the existence of a trust meant there was no violation of a legal right by UCPB, and thus no cause of action against the bank. The petition was denied for lack of merit.