- Petitioner
- Teofisto Guingona, Jr.
- Respondent
- The City Fiscal of Manila
- Citation
- G.R. No. 60033
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Makasiar, J.
- Decided
- April 4, 1984
Summary
This case involved a petition for prohibition to stop criminal proceedings against bank officers charged with estafa and Central Bank violations. Clement David invested over P1 million and US$75,000 with Nation Savings and Loan Association. When the bank was placed under receivership, officers Guingona and Martin assumed the obligations via promissory notes. David later filed criminal charges claiming misappropriation. The Supreme Court ruled that bank deposits are simple loans under Article 1980 of the Civil Code, creating a creditor-debtor relationship, not a trust relationship. The novation through promissory notes before the criminal complaint was filed converted any potential criminal liability into purely civil liability. The decision clarifies the legal nature of bank deposits and the effect of novation on criminal liability.