Sps. Cristino & Edna Carbonell · G.R. 178467

Petitioner: Sps. Cristino & Edna Carbonell
Respondent: Metropolitan Bank
Citation: G.R. No. 178467
Court: Supreme Court
Division: Third Division
Ponente: Bersamin, J.
Decided: April 26, 2017

Summary

Spouses Carbonell sued Metropolitan Bank for moral damages after suffering public humiliation in Thailand when US$100 bills withdrawn from the bank were discovered to be counterfeit. The couple claimed embarrassment when a Bangkok bank confiscated one fake bill and a jewelry shop owner publicly called them cheaters. BSP certified the bills were 'near perfect genuine notes' difficult to detect even with due diligence. The Supreme Court applied the damnum absque injuria principle, ruling that while the couple suffered damage, no legal injury occurred since the bank exercised proper protocols and showed no bad faith or gross negligence. The Court emphasized that moral damages for breach of contract require fraudulent conduct or bad faith under Article 2220 of the Civil Code, which was absent. The bank's offer of settlement was deemed not an admission of liability.

Statutes applied

Civil Code, Art. 2220

Related cases

Other Philippine cases on the same provisions and issues.

Francisco v. Ferrer, Jr. G.R. No. 142029
Far East Bank v. The Honorable Court of Appeals G.R. No. 108164
Gemma A. Vda. de Liwag v. Rudy P. Cruz [Deceased] G.R. No. 259415
Dr. Enrique T. Ona v. Northstar International Travel G.R. No. 209581
Philippine Airlines v. Vicente Lopez, Jr. G.R. No. 156654
Teodoro I. Chavez v. Hon. Court of Appeals G.R. No. 159411
Mariano L. del Mundo v. Hon. Court of Appeals G.R. No. 104576
Spouses Danilo Febrero v. Spouses Rodolfo Febrero G.R. No. 262227

By the Intellegal Editorial Board · April 26, 2017

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