GR 178467; (April, 2017) (Digest)
G.R. No. 178467 , April 26, 2017
SPS. CRISTINO & EDNA CARBONELL, Petitioners, vs. METROPOLITAN BANK AND TRUST COMPANY, Respondent.
FACTS
Petitioners Spouses Carbonell withdrew US$1,000 in $100 bills from their dollar account with respondent Metrobank’s Pateros branch. During a trip to Bangkok, Thailand, they attempted to exchange the bills. One bill was immediately rejected as counterfeit by a foreign exchange dealer and later confiscated by a local bank. Subsequently, when using four other bills to purchase jewelry, the shop owner publicly confronted and humiliated them in their hotel lobby after declaring those bills fake. Upon their return, the petitioners demanded damages from Metrobank. The Bangko Sentral ng Pilipinas later examined four of the returned bills and certified them as “near perfect genuine notes.” Metrobank, while expressing sympathy, denied liability, stating it could not absolutely guarantee every foreign currency note and that it too was a victim. It offered to reinstate US$500 and underwrite a trip, which the petitioners refused.
ISSUE
Whether respondent Metrobank is liable for damages due to negligence or breach of its fiduciary duty for releasing allegedly counterfeit US dollar bills to the petitioners.
RULING
The Supreme Court ruled that Metrobank is not liable. While banks are held to the highest standards of diligence under the General Banking Act, liability is determined based on the circumstances of each case. The Court found no evidence of gross negligence, misrepresentation, or bad faith on the part of the bank. The bank’ standard operating procedures for handling foreign currency, which included verification by trained tellers and sourcing notes from reputable suppliers, constituted the diligence required by the nature of its obligation. The fact that the BSP later certified the notes as “near perfect” indicated the sophistication of the counterfeits, supporting the bank’s claim that even experts could be deceived. The bank’s offer of compromise was not an admission of liability. The damage suffered by the petitioners, while unfortunate, occurred without any legal wrong or breach of duty by the bank, constituting damnum absque injuria (damage without injury). Therefore, no basis for an award of moral or exemplary damages existed. The Court affirmed the dismissal of the complaint but deleted the award of attorney’s fees, as the petitioners’ suit was filed in good faith.