G.R. No. 202514, July 25, 2016 - ANNA MARIE L. GUMABON, Petitioner, v. PHILIPPINE NATIONAL BANK, Respondent.

ANNA MARIE L. GUMABON, v. PHILIPPINE NATIONAL BANK

G.R. No. 202514, July 25, 2016

Facts:

The case stemmed from the PNB's refusal to release Anna Marie's money in a consolidated savings account and in two foreign exchange time deposits, evidenced by Foreign Exchange Certificates of Time Deposit (FXCTD).

Anna Marie decided to consolidate the eight (8) savings accounts and to withdraw P-2,727,235.85 from the consolidated savings account to help her sister's financial needs.  After withdrawals, the balance of her consolidated savings account was P250,741.82.

On July 30, 2003, the PNB sent letters to Anna Marie to inform her that the PNB refused to honor its obligation under FXCTD Nos. 993902 and 993992, and that the PNB withheld the release of the balance of P-250,741.82 in the consolidated savings account. According to the PNB, Anna Marie pre-terminated, withdrew and/or debited sums against her deposits. On August 12, 2004, Anna Marie filed a complaint for recovery of sum of money and damages before the RTC against the Philippine National Bank (PNB) and the PNB Delta branch manager Silverio Fernandez

Issue:

Whether or not PNB is liable to the time deposit and the remaining bank deposit of Anna Marie

Ruling:

Yes, PNB failed to establish the fact of payment to Anna Marie in FXCTD Nos. 993902 and 993992, and SA No. 6121200. It is a settled rule in evidence that the one who alleges payment has the burden of proving it.           

The PNB alleged that it had already paid the balance of the consolidated savings account (SA No. 6121200) amounting to P-250,741.82. It presented the manager's check to prove that Anna Marie purchased the check using the amounts covered by the Gumabon's two savings accounts which were later part of Anna Marie's consolidated savings account. The PNB also presented the miscellaneous ticket to prove Anna Marie's withdrawal from the savings accounts.

            The business of banking is imbued with public interest. The stability of banks largely depends on the confidence of the people in the honesty and efficiency of banks. In every case, the depositor expects the bank to treat his account with the utmost fidelity, whether such account consists only of a few hundred pesos or of millions. The bank must record every single transaction accurately, down to the last centavo, and as promptly as possible.