Oblicon Digests
Michael Anthony L. Leachon
Obligation and Contracts Case Digests
PNB VS CA 315 SCRA 309
FACTS:
* October 23, 1990 Lily S. Pujol opened an account with the petitioner PNB(Mandaluyong branch.) She applied for a “combo account” under her business name “Pujol Trading.” This account is a combination of a savings and current account wherein if there are insufficient funds in the current account of the owner then the funds of the savings fund will be used. PNB thereafter, issued a passbook with the words: “Combo Deposit Plan” in the cover. * On October 23, 1990 Lily issued a check worth 30,000 php to her daughter in law, Dr. Charisse M. Pujol. Even though she had sufficient funds in her saving account the bank dishonored the check for insufficiency of funds and charger her 250php as penalty. * On October 24, 1990 Lily again issued another check (she still has sufficient funds) amounting to 30000 php to her daughter Ms. Venus P. De Ocampo. The bank again dishonored the check and charged her a penalty of 250 php. * On November 4, 1990 realizing their mistake petitioner PNB accepted the 2nd check and recredited the 250php penalty to her account. * Respondent filed a complaint for moral and exemplary damages to RTC of Pasig because of dishonoring her checks even if she had sufficient money. * On September 27, 1994 the RTC issued a decision ordering PNB to pay her moral damages of 100000php and 20000php for attorney fees. * Petitioner erred and argued that at that time she was missing some important documents that is why her account was not yet activated.
ISSUES:
* W/N PNB is liable for damages.
DECISION:
* It is immaterial. The facts that PNB gave her a passbook with the words “Combo Deposit Account” mislead her to believe that her account was already active. * The courts said that the bank is under obligation to treat the accounts of its depositors with meticulous care whether such accounts consists only of a few hundred or
Obligation and Contracts Case Digests
PNB VS CA 315 SCRA 309
FACTS:
* October 23, 1990 Lily S. Pujol opened an account with the petitioner PNB(Mandaluyong branch.) She applied for a “combo account” under her business name “Pujol Trading.” This account is a combination of a savings and current account wherein if there are insufficient funds in the current account of the owner then the funds of the savings fund will be used. PNB thereafter, issued a passbook with the words: “Combo Deposit Plan” in the cover. * On October 23, 1990 Lily issued a check worth 30,000 php to her daughter in law, Dr. Charisse M. Pujol. Even though she had sufficient funds in her saving account the bank dishonored the check for insufficiency of funds and charger her 250php as penalty. * On October 24, 1990 Lily again issued another check (she still has sufficient funds) amounting to 30000 php to her daughter Ms. Venus P. De Ocampo. The bank again dishonored the check and charged her a penalty of 250 php. * On November 4, 1990 realizing their mistake petitioner PNB accepted the 2nd check and recredited the 250php penalty to her account. * Respondent filed a complaint for moral and exemplary damages to RTC of Pasig because of dishonoring her checks even if she had sufficient money. * On September 27, 1994 the RTC issued a decision ordering PNB to pay her moral damages of 100000php and 20000php for attorney fees. * Petitioner erred and argued that at that time she was missing some important documents that is why her account was not yet activated.
ISSUES:
* W/N PNB is liable for damages.
DECISION:
* It is immaterial. The facts that PNB gave her a passbook with the words “Combo Deposit Account” mislead her to believe that her account was already active. * The courts said that the bank is under obligation to treat the accounts of its depositors with meticulous care whether such accounts consists only of a few hundred or