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The Metropolitan Bank Trust Company Vs Ana Grace Rosales and Yo Yuk To

Metropolitan Bank filed a "Hold Out" order against Rosales and Yo Yuk To's accounts and a criminal case for estafa, claiming Rosales took part in an unauthorized withdrawal from another customer's account. Rosales denied this and filed a breach of contract case. The Supreme Court found that Metropolitan Bank breached its contract by refusing to release the deposits despite demand, as the bank failed to show Rosales had any obligation under law or contract. Banks can protect themselves from fraud but must do so within legal bounds and not in bad faith or disregard of contractual obligations.

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3K views1 page

The Metropolitan Bank Trust Company Vs Ana Grace Rosales and Yo Yuk To

Metropolitan Bank filed a "Hold Out" order against Rosales and Yo Yuk To's accounts and a criminal case for estafa, claiming Rosales took part in an unauthorized withdrawal from another customer's account. Rosales denied this and filed a breach of contract case. The Supreme Court found that Metropolitan Bank breached its contract by refusing to release the deposits despite demand, as the bank failed to show Rosales had any obligation under law or contract. Banks can protect themselves from fraud but must do so within legal bounds and not in bad faith or disregard of contractual obligations.

Uploaded by

Gretchen
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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The Metropolitan Bank Trust Company vs Ana Grace Rosales and Yo Yuk To

G.R. No. 183204, January 13, 2014

FACTS:
Petitioner Metrobank is a domestic banking corporation duly organized and existing under the laws of the
Philippines. Respondent Rosales is the owner of a travel agency while Yo Yuk To is her mother. In 2000, respondents
opened a Joint Peso Account with petitioner’s Pritil-Tondo Branch. In May 2002, Rosales accompanied her client Liu
Chiu Fang, a Taiwanese National applying for a retiree’s visa from the Philippine Leisure and Retirement Authority
(PLRA), to petitioner’s branch in Escolta to open a savings account. Since Liu Chiu Fang could speak only in
Mandarin, respondent Rosales acted as an interpreter for her. On March 3, 2003, respondents opened with petitioner’s
Pritil-Tondo Branch a Joint Dollar Account with an initial deposit of US$14,000.00.
On July 31, 2003, petitioner issued a “Hold Out” order against respondents’ accounts and filed before the
Office of the Prosecutor of Manila a criminal case for Estafa through False Pretences, Misrepresentation, Deceit, and
Use of Falsified Documents claiming that Rosales took part in the fraudulent and unauthorized withdrawal from the
dollar account of Liu Chiu Fang. Respondent denied the same and filed a Complaint for Breach of Contract. Thus,
this petition.

ISSUE:
WON Metrobank breached its contract with respondents.
HELD:
Yes. Bank deposits, which are in the nature of a simple loan or mutuum, must be paid upon demand by the
depositor. The “Hold Out” clause applies only if there is a valid and existing obligation arising from any of the sources
of obligation enumerated in Article 1157 of the Civil Code, to wit: law, contracts, quasi-contracts, delict, and quasi-
delict. In this case, petitioner failed to show that respondents have any obligation to it under any law, contract, quasi-
contract, delict, or quasi-delict. Thus, the Court found that petitioner is guilty of breach of contract when it
unjustifiably refused to release respondents’ deposit despite demand.
While the Court recognize that petitioner has the right to protect itself from fraud or suspicions of fraud, the
exercise of his right should be done within the bounds of the law and in accordance with due process, and not in bad
faith or in a wanton disregard of its contractual obligation to respondents.

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