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    PNB vs. Santos - G.R. No. 208293 - Dec 10, 2014

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    PNB vs. Santos - G.R. No. 208293 - Dec 10, 2014

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    veronicabanares
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    2. PNB vs. Santos_G.R. No. 208293_Dec 10, 2014

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    PNB vs. Santos - G.R. No. 208293 - Dec 10, 2014

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    COMMERCIAL LAW I

    CASE DIGEST FOR CHAPTER 4

    Philippine National Bank vs. Santos


    G.R. No. 208293, December 10, 2014

    Facts:
    The case involves the Philippine National Bank (PNB) and its branch
    manager, Lina B. Aguilar, as petitioners, against the respondents, who are
    the children of the deceased Angel C. Santos. Angel C. Santos passed away
    on March 21, 1991. In May 1996, the respondents discovered that their
    father had a premium savings account and a time deposit with PNB's Sta.
    Elena-Marikina City Branch, amounting to P1,759,082.63 and
    P1,000,000.00, respectively. When the respondents attempted to withdraw
    these deposits in April 1998, they were informed by Aguilar that the
    deposits had already been released to Bernardito Manimbo on April 1, 1997.
    Manimbo had presented an affidavit of self-adjudication, a certificate of time
    deposit, and a death certificate, among other documents. PNB required
    several documents for the withdrawal, but ultimately released the funds to
    Manimbo based on incomplete documentation, without the necessary BIR
    certification confirming the payment of estate taxes. The respondents filed a
    complaint for a sum of money and damages against PNB, Aguilar, and a
    John Doe, arguing that the release of the deposit to Manimbo was
    unauthorized and lacked proper documentation. The Regional Trial Court of
    Marikina City found PNB and Aguilar jointly and severally liable for
    P1,882,002.05, plus interest, moral and exemplary damages, attorney's
    fees, and costs of suit. The Court of Appeals affirmed the trial court's
    decision but modified the interest rate and deleted the award for exemplary
    damages. PNB and Aguilar then filed separate petitions for review.

    Issue:
    1. Whether PNB was negligent in releasing the deposit to Manimbo.
    2. Is Lina B. Aguilar jointly and severally liable with the PNB for the release
    of the deposit to Bernardito Manimbo?

    Held:
    The Supreme Court affirmed the decision of lower courts.
    COMMERCIAL LAW I
    CASE DIGEST FOR CHAPTER 4

    Ruling:
    PNB and Aguilar were negligent in handling the deposit of Angel C. Santos
    as banks are held to a higher standard of diligence than that of a good
    father of a family due to their fiduciary relationship with depositors. The
    Court found that PNB and Aguilar failed to adhere to their own requirements
    for releasing the deposit, particularly the lack of a BIR certification, which is
    mandated by law before any withdrawal from a deceased depositor's
    account. The Court also highlighted that the negligence of PNB and Aguilar
    constituted gross negligence, justifying the award of moral and exemplary
    damages.

    Principle:
    The standard of diligence required of banks is higher than that of a good
    father of a family, as banks are businesses affected by public interest and
    must treat depositor accounts with utmost care.
    The failure to observe the required diligence constitutes gross negligence,
    which justifies the award of moral and exemplary damages to the heirs.

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