Bank of the Philippine Islands v. Amado M. Mendoza

Summary

BPI filed a complaint against the Mendozas for return of funds withdrawn from a dishonored US Treasury check. Respondents deposited the check worth US$16,164.00, withdrew the funds after the clearing period, but the check was later dishonored due to alteration. The RTC ruled for BPI based on solutio indebiti principles, but the CA reversed for failure to prove check dishonor due to evidentiary issues. The Supreme Court reinstated the RTC decision, finding that BPI sufficiently proved its case through Amado's acknowledgment letters and promissory note. The Court held the photocopy of the confiscated check was admissible under the Best Evidence Rule exception, and modified the interest rate from 12% to 6% per annum since the obligation arose from payment by mistake rather than a loan. The case establishes the principle that banks can recover funds paid on subsequently dishonored checks through quasi-contractual obligations under solutio indebiti.