Bpi Express Card Corporation v. Court of Appeals

Summary

This Supreme Court case involved a credit card holder's claim for damages after his BPI Express Card was dishonored at a restaurant, causing public embarrassment. Atty. Ricardo Marasigan sued BPI Express Card Corporation for moral and exemplary damages, claiming the company abused its right in suspending his card despite his issuance of a postdated check for payment. The trial court and Court of Appeals both awarded damages, finding an abuse of right under Civil Code Article 19. However, the Supreme Court reversed, holding that BPI had a clear contractual right to suspend the card after 30 days of non-payment, that a postdated check does not constitute effective payment, and that no abuse of right occurred. The Court applied the damnum absque injuria principle, finding that while Marasigan suffered damage, there was no legal injury since BPI acted within its contractual rights. The case establishes important precedents on credit card contract interpretation, the legal effect of postdated checks as payment, and the requirements for proving abuse of right under Article 19.