Philippine Development & Industrial Corporation v. Equitable Pci Bank (Now Known As Banco de Oro-Epci

Summary

PDIC obtained credit facilities totaling P250 million from EPCIB to finance a condominium project. While EPCIB released the clean credit line proceeds, it refused to release funds from the approved secured credit line, citing market conditions and discretionary review powers. This forced PDIC to seek alternative financing and enter disadvantageous agreements. The Supreme Court found that EPCIB's unilateral discretion to cancel or modify approved credit facilities violated the principle of mutuality of contracts under Article 1308 of the Civil Code, making such clauses void and potestative. While EPCIB was liable for breach of contract, PDIC failed to prove actual damages with sufficient evidence. The Court awarded temperate damages of P400,000 and attorney's fees of P100,000, recognizing that economic damage occurred but could not be quantified with certainty due to inadequate proof.