G.R. No. 208672 , December 07, 2016
Philippine National Bank v. Pablo V. Raymundo

FACTS

Respondent Pablo V. Raymundo, then Department Manager of PNB San Pedro Branch, approved the deposit of a foreign draft check for $172,549.00 payable to Merry May Juan and the subsequent payment of six checks drawn by Juan against this deposit, totaling ₱4,000,000.00, on the same day. The foreign draft check was later dishonored by the drawee bank as fraudulent. PNB suffered a loss as the funds had already been paid out. Raymundo was administratively charged by PNB and later criminally charged with violation of Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) for allegedly approving the payments with gross inexcusable negligence, causing undue injury to the bank. The Regional Trial Court acquitted Raymundo of the criminal charge, a decision affirmed by the Court of Appeals. PNB then filed this petition, seeking to hold Raymundo civilly liable for the bank’s loss.

ISSUE

Whether respondent Pablo V. Raymundo can be held civilly liable to PNB for the loss arising from his alleged negligent acts, notwithstanding his acquittal in the criminal case for violation of R.A. No. 3019 .

RULING

No. The Supreme Court denied the petition and affirmed the lower courts’ decisions, ruling that Raymundo cannot be held civilly liable. The legal logic is anchored on the source of obligation. A civil action arising from a crime, known as ex delicto, requires the civil liability to be based on the criminal act. Since Raymundo was acquitted because his actions did not constitute the crime charged—the prosecution failed to prove gross inexcusable negligence or any criminal intent beyond reasonable doubt—no civil liability ex delicto can arise. The Court emphasized that the acquittal was based on the finding that Raymundo acted in good faith, relying on established bank procedures where subordinate officers were responsible for verifying account balances and flagging unfunded checks. His approval was a ministerial act based on the absence of a return slip from the bookkeeper, indicating the checks were funded. Consequently, there is no actionable civil wrong rooted in the criminal charge. Any potential civil liability would have to be based on a separate source of obligation, such as contract or quasi-delict, which was not pleaded or proven in this case. The loss is attributable to the fraudulent acts of the account holder, Merry May Juan, against whom Raymundo had already filed charges.