G.R. No. 156311 . December 16, 2005
CENTRAL BANK OF THE PHILIPPINES, Petitioner, vs. AURORA P. CASTRO, Respondent.

FACTS

The Central Bank of the Philippines filed a complaint to recover ₱100,000 from its former employee, Aurora P. Castro, the Chief of the Tellers Division. Petitioner alleged that on February 24, 1987, an accountable officer, Elisa de Vera, inadvertently included an extra, improperly tied bundle of ₱100,000 in the cash transfer to respondent’s vault. This extra bundle was not reflected in the official Cash Transfer Slips, which de Vera and Castro both signed, indicating receipt only of the bundles listed therein. De Vera discovered the shortage later that day. The Bank’s claim relied heavily on de Vera’s testimony and the subsequent account of a currency laborer, Antonio Dagot, who claimed he later tied the stray bundle and delivered it to Castro’s assistant inside her vault.
Respondent Castro denied liability. She asserted that she received and verified only the bundles listed in the signed Cash Transfer Slips, after which de Vera and Dagot left with the emptied transport carts. She maintained that any delivery by Dagot of an extra bundle after the formal transfer and without her personal receipt was irregular and not her responsibility. Both the trial court and the Court of Appeals dismissed the complaint, finding the Bank’s evidence insufficient to prove by preponderance that Castro actually received the disputed ₱100,000.

ISSUE

Whether the Court of Appeals erred in affirming the dismissal of the complaint for recovery of a sum of money, thereby upholding the finding that petitioner failed to prove its claim by preponderance of evidence.

RULING

The Supreme Court denied the petition and affirmed the appellate court’s decision. The Court emphasized that in a petition for review under Rule 45, only questions of law may be raised. The core issue—the sufficiency of evidence to prove receipt of the money—is factual. The findings of fact of the trial court, affirmed by the Court of Appeals, are generally conclusive and binding.
The legal logic rests on the principle that in civil cases, the burden of proof lies with the plaintiff, who must establish its case by a preponderance of evidence. The Bank failed to discharge this burden. The signed Cash Transfer Slips, the best evidence of the transaction, only covered the bundles listed and did not include the extra ₱100,000. De Vera’s testimony was deemed insufficient to overturn the presumption of regularity in the official transaction documented by the slips. The alleged subsequent delivery by Dagot was uncorroborated and, critically, did not involve Castro’s personal acknowledgment or a proper official receipt. The Court found no compelling reason to deviate from the lower courts’ uniform assessment that the evidence for the Bank was weak and unreliable. Consequently, without proof that Castro actually received the disputed amount, no obligation to return it arose.