- Petitioner
- Joseph Goyanko, Jr.
- Respondent
- United Coconut Planters Bank
- Citation
- G.R. No. 179096
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Brion, J.
- Decided
- February 6, 2013
Summary
The Supreme Court denied the petition seeking to hold United Coconut Planters Bank liable for allowing withdrawal from an account designated 'ITF (In Trust For) The Heirs of Joseph Goyanko, Sr.' The Court ruled that no express trust existed between the deposit holder PALII and the bank UCPB. The essential elements for express trust creation were absent, including competent trustor-trustee relationship and clear intention to create trust with reasonable certainty of terms. The Court found that despite the 'ITF' designation, the account represented an ordinary creditor-debtor deposit relationship under Civil Code Article 1980, where UCPB properly fulfilled its contractual obligation to allow the account holder PALII to withdraw funds. The bank was not charged with constructive notice of any trust arrangement merely from the account designation. The decision clarifies the distinction between ordinary bank deposits and express trusts, emphasizing that fiduciary language alone is insufficient to establish trust relationships without meeting all legal requirements for trust creation.