GR 115997; (November, 2000) (Digest)
G.R. No. 115997 ; November 27, 2000
SECURITY BANK & TRUST COMPANY, petitioner, vs. COURT OF APPEALS and TRANSWORLD ENTERPRISES and TURIANO SAN ANDRES, respondents.
FACTS
Petitioner Security Bank & Trust Company (SBTC) filed a collection case against respondents Transworld Enterprises and Turiano San Andres for the unpaid obligation under Trust Receipt No. 77/0007, covering a domestic letter of credit with a principal value of ₱250,000.00. Respondents had made a 30% marginal deposit of ₱75,000.00 and subsequently made several payments. The core dispute centered on the proper basis for computing interest and bank charges. SBTC insisted on a “gross amount computation,” applying interest to the full ₱250,000.00 face value without deducting the marginal deposit. Conversely, respondents advocated for a “net of marginal deposit computation,” arguing that interest should be calculated only on the net loaned amount of ₱175,000.00 after the deposit.
During pre-trial, both parties agreed on the aggregate sum of payments made. The trial court found that SBTC had previously applied the net computation method to respondents’ other letters of credit. SBTC relied on Banker’s Association of the Philippines (BAP) guidelines and the testimony of its officer, Lina Gobencion, to justify its gross computation stance for the subject transaction.
ISSUE
Whether the computation of interest and bank charges on the letter of credit covered by the trust receipt should be based on the gross amount of ₱250,000.00 or on the net amount of ₱175,000.00 after deducting the marginal deposit.
RULING
The Supreme Court affirmed the Court of Appeals’ decision, upholding the net of marginal deposit computation. The Court found no reversible error in the factual conclusions of the lower courts, which are binding when supported by evidence. Critically, the Court noted petitioner’s admission in its appellate brief that it had allowed the net computation for respondents’ previous letters of credit, contradicting its present claim of consistent gross computation. The trust receipt and letter of credit application were contracts of adhesion prepared by SBTC.
These documents stipulated only the interest rate and the marginal deposit percentage but were silent on the specific method for computing interest relative to the deposit. Applying Article 1377 of the Civil Code, any obscurity in the contract’s stipulations must be interpreted strictly against the party who caused it—the bank—and liberally in favor of the other party. Therefore, the ambiguity regarding computation was resolved in favor of respondents’ position, which was consistent with the bank’s own prior conduct. The Court found no legal basis in the invoked BAP rules to mandate an exclusion of the marginal deposit from the interest computation base.