G.R. No. 229450 , June 17, 2020
PHILIPPINE SAVINGS BANK, PETITIONER, V. MARIA CECILIA SAKATA, RESPONDENT.

FACTS

Respondent Maria Cecilia Sakata maintained savings and current accounts with petitioner Philippine Savings Bank (PS Bank). After working abroad from 2003 to 2006, she discovered upon her return that her savings account balance was nearly depleted. An investigation revealed 25 checks, totaling P1,087,500, had been debited from her account. Sakata claimed these checks were forged, as she did not possess the checkbook bearing their serial numbers and was overseas when they were encashed. She demanded PS Bank re-credit the amount, but the bank refused, asserting the checks were validly issued and encashed, allegedly with authorization from Sakata’s mother.

ISSUE

Whether PS Bank is liable to reimburse Sakata for the amounts paid out on the allegedly forged checks.

RULING

Yes. The Supreme Court affirmed the lower courts’ decisions, holding PS Bank liable. The legal logic rests on the established doctrine that a bank is bound to know the signatures of its customers. In paying a forged check, the bank is considered to have paid out its own funds and cannot charge the depositor’s account. The burden of proving the checks were genuine lay with PS Bank. The Court found PS Bank failed to discharge this burden. Its evidence, including a check requisition form and an updated signature card, was deemed unreliable as Sakata was proven to be abroad when these documents were purportedly executed. The bank’s failure to produce the original checks for examination further weakened its defense. Consequently, the loss from the forgery falls on the bank, which did not exercise the high degree of diligence required in handling depositors’ accounts. The Court ordered PS Bank to pay Sakata the principal sum with legal interest.