G.R. No. 205590, September 02, 2015
Philippine National Bank, Petitioner, vs. Ligaya M. Pasimio, Respondent.

FACTS

Respondent Ligaya M. Pasimio filed a complaint for sum of money and damages against petitioner Philippine National Bank (PNB) before the Regional Trial Court (RTC) of Parañaque City. She alleged she had peso and dollar time deposit accounts with PNB totaling P4,322,057.57 and US$5,170.80, which had matured, but PNB refused to allow her to withdraw the deposits and accrued interests. PNB, in its Answer, admitted the deposits but claimed they were legally set off against Pasimio’s outstanding loan obligations. PNB presented evidence that Pasimio and her husband obtained three “loans against deposit hold-out” from the PNB Sucat branch on March 21, 2001 (P3,100,000), April 2, 2001 (P1,700,000), and December 7, 2001 (US$31,100), each secured by her deposit accounts. PNB submitted loan application forms, promissory notes with a “hold-out” clause, disclosure statements, and evidence of the release of proceeds via manager’s checks and cash. Pasimio denied obtaining any loans or receiving proceeds. She testified she signed the loan documents in blank, believing they were for new high-yielding deposit products, due to the misrepresentations of PNB officers Teresita Gregorio and Gloria Miranda, who were later dismissed for involvement in anomalous loan transactions. Pasimio also denied re-lending proceeds to a certain Paolo Sun, claiming Gregorio prepared an affidavit about such a loan to cover up the scheme. The RTC ruled in favor of Pasimio, ordering PNB to pay her the deposit amounts with interest. The Court of Appeals affirmed the RTC decision. PNB appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the RTC decision which held that no loan transaction existed between Pasimio and PNB and that PNB was liable to return Pasimio’s deposits with interest.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals decision. The Court held that the factual findings of the RTC, affirmed by the CA, are generally conclusive and binding. It found no compelling reason to deviate from these findings, as PNB failed to prove any of the recognized exceptions warranting a review of facts. The Court agreed with the lower courts that PNB failed to prove the existence of a valid loan contract. The evidence showed irregularities: the loan proceeds were not actually delivered to Pasimio (the manager’s checks were not encashed by her, and there was no proof she received the dollar loan cash), and the loan documents were signed in blank under deceptive circumstances orchestrated by PNB’s own officers. The “hold-out” agreement in the promissory notes, which would authorize PNB to apply the deposits to the loan, was void due to the absence of a principal loan obligation. Furthermore, PNB failed to overcome the presumption that money deposited with a bank is to be paid to the depositor upon demand. The dismissal of the involved PNB officers for irregular lending practices corroborated Pasimio’s claim of a scam. Therefore, PNB was ordered to pay Pasimio the value of her deposits with legal interest.