Producers Bank of the Philippines (Now First International Bank) v. Hon. Court of Appeals

Summary

This case involves a bank's liability for unauthorized withdrawals facilitated by employee connivance. Franklin Vives accommodated Col. Doronilla by depositing P200,000 in Sterela Marketing's account for incorporation purposes under a commodatum arrangement. Bank Assistant Manager Atienza, knowing the money belonged to Vives, improperly allowed Doronilla to withdraw funds without required authorization or passbook presentation. The Supreme Court upheld lower court decisions finding the bank solidarily liable under Article 2180 of the Civil Code for its employee's wrongful acts committed within the scope of employment. The Court distinguished between commodatum and mutuum contracts, ruling this was an accommodation loan where ownership remained with Vives. The decision establishes important precedent on banking liability for employee misconduct and proper classification of loan agreements in Philippine jurisprudence.