G.R. No. 273446 & 273493, April 23, 2025
ANGELITA A. ANTONINO, PETITIONER, vs. BANCO DE ORO UNIVERSAL BANK, INC., RESPONDENT. [G.R. No. 273493] BANCO DE ORO UNIVERSAL BANK, INC., PETITIONER, vs. REMEDIOS A. ANTONINO AND ANGELITA A. ANTONINO, RESPONDENTS.

FACTS

Remedios A. Antonino and Angelita A. Antonino made several time deposit placements with Banco De Oro Universal Bank, Inc. (BDO) at its San Lorenzo Branch. These included a deposit of USD 50,007.71 on December 10, 1998, a deposit of USD 50,000.70 on July 26, 2000, and a total deposit of USD 50,000.70 on February 26, 2001, covered by three Time Deposit Certificates (TDCs). They alleged an agreement with the bank manager for automatic roll-over of the placements if not claimed on the due dates, as they were often abroad. The TDCs were stored in a safety deposit box at Banco Filipino, which later declared bankruptcy and was placed under PDIC receivership, delaying the retrieval of the certificates. BDO San Lorenzo also ceased operations without notice. Upon retrieving the TDCs and inquiring with BDO in 2014, the bank initially asked for time to investigate but later claimed, via a July 22, 2015 letter, that the three TDCs from February 2001 (Nos. 1193123, 1193124, 1193125) had been redeemed and paid on May 28, 2001. BDO presented a computer-printed history showing a series of roll-overs from a single initial investment and a Demand Draft allegedly signed by Angelita for the withdrawal. Angelita countered that she was not in the Philippines on that date, supported by a Bureau of Immigration Certification and her passport. A handwriting expert from the PNP Crime Laboratory testified that the signature on the Demand Draft was dissimilar to Angelita’s standard signatures but could not give a definite conclusion due to the poor quality of the carbon copy. Remedios and Angelita filed a complaint for payment of their total time deposit claim of USD 150,008.41, exclusive of interest.

ISSUE

Whether the Court of Appeals erred in affirming the Regional Trial Court’s decision ordering BDO to pay Remedios and Angelita Antonino the amount of USD 100,000.70 plus interest, exemplary damages, and attorney’s fees.

RULING

The Supreme Court denied the petitions and affirmed the assailed Court of Appeals Decision and Resolution. The Court held that BDO failed to prove by preponderance of evidence that the time deposit placements had been paid. The bank’s reliance on its internal computer-generated records and the disputed Demand Draft was insufficient, especially against the respondents’ evidence, including proof of Angelita’s absence from the country on the alleged redemption date. The existence of the TDCs, which were negotiable instruments, gave rise to the presumption that the obligation remained unpaid. BDO’s failure to present the original Demand Draft or other conclusive proof of payment rendered its defense unsubstantiated. The award of exemplary damages and attorney’s fees was justified due to BDO’s gross negligence in record-keeping and failure to properly inform its clients of the branch closure, which amounted to bad faith. The Court modified the interest award, stating that for the unredeemed time deposits (the 1998 and 2000 placements), the stipulated interest should run only until their respective maturity dates, after which legal interest at 6% per annum would apply from judicial demand until full payment.