GR 165339; (August, 2010) (Digest)
G.R. No. 165339 ; August 23, 2010
EQUITABLE PCI BANK, Petitioner, vs. ARCELITO B. TAN, Respondent.
FACTS
Respondent Arcelito Tan maintained accounts with petitioner Equitable PCI Bank. On May 13, 1992, he issued PCIB Check No. 275100, which he claimed was postdated to May 30, 1992, in favor of Sulpicio Lines, Inc. His account balance on May 14 was ₱35,147.59. The check was deposited and, after clearing, petitioner debited the amount of ₱34,588.72 from his account on May 14, leaving a minimal balance. Subsequently, three other checks issued by respondent between May 9 and 16, 1992, were dishonored for insufficiency of funds.
The dishonor of two checks payable to electric cooperatives resulted in the disconnection of power to respondent’s two mini-sawmills, allegedly causing substantial business losses. Respondent filed a complaint for damages, contending that the bank was negligent in debiting the postdated check before its stated date, thereby causing the insufficiency that led to the dishonor of his other checks and the resulting business losses.
ISSUE
The primary issue was whether the bank was negligent in debiting the account, making it liable for the damages arising from the dishonor of the respondent’s other checks.
RULING
The Supreme Court ruled in favor of the petitioner bank and reversed the Court of Appeals. The Court found that Check No. 275100 was not postdated but was a current check dated May 3, 1992. The respondent’s own evidence, including a microfilm copy of the check, clearly showed the date “May 3, 1992.” The respondent’s peculiar way of writing the numeral “3” to resemble “30” was the proximate cause of the confusion and the subsequent dishonor of his other checks.
The Court held that a bank is only obligated to honor a check according to its tenor. Upon its clear presentment, the bank correctly treated it as a current check payable immediately. There was no negligence on the part of the bank in performing its contractual duty. The respondent’s failure to maintain sufficient funds to cover all his issued checks was the direct cause of the dishonors. Consequently, the awards for actual, moral, and exemplary damages, as well as attorney’s fees, were deleted for lack of basis. The bank’s adherence to standard banking procedure absolved it of liability.