Philippine Bank of Commerce… · G.R. 97626

Petitioner: Philippine Bank of Commerce
Respondent: The Court of Appeals
Citation: G.R. No. 97626
Court: Supreme Court
Division: First Division
Decided: March 14, 1997

Summary

This Supreme Court case involved a banking dispute where RMC's secretary fraudulently diverted company deposits totaling P304,979.74 to her husband's account over 14 months. The bank teller negligently validated incomplete duplicate deposit slips, facilitating the fraud. The Court applied quasi-delict principles under Article 2176 of the Civil Code, finding the bank's negligence as the proximate cause due to failure to follow proper validation procedures and inadequate employee supervision. However, recognizing RMC's contributory negligence in not checking monthly statements, the Court allocated damages on a 60-40 ratio, with the bank bearing primary liability. The decision established important precedents on banking fiduciary duties and the 'last clear chance' doctrine in negligence cases.

Statutes applied

Civil Code, Art. 2176

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By the Intellegal Editorial Board · March 14, 1997

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