Philippine National Bank v. Court of Appeals

Summary

PNB was court-ordered to release P32,480.00 expropriation proceeds to landowner Loreto Tan. Instead, PNB's assistant manager issued the check to Sonia Gonzaga based on an alleged Special Power of Attorney that was never produced in court. Tan denied authorizing Gonzaga and sued for recovery. The Supreme Court applied the best evidence rule, ruling that without the original SPA document, PNB failed to prove valid payment. Under Article 1233 of the Civil Code, no payment occurred since the money was not delivered to the rightful recipient. The Court affirmed PNB's liability for P32,480.00 with interest and attorney's fees, but deleted exemplary damages for lack of bad faith. The case establishes the strict requirement of proper payment to designated recipients and the necessity of producing original documents when their contents are in dispute.