Premiere Development Bank v. Manalo

A drawee bank that negligently allows an unauthorized withdrawal from its depositor's account and a collecting bank that heedlessly endorses and clears a crossed check payable to a named payee but credits it to another's account are both liable for the loss, with liability apportioned based on their comparative negligence. The collecting bank that stamps its endorsement guaranteeing all prior indorsements on a crossed check bearing "For Payee's Account Only" is solely liable to the payee for the face value of the check.

Primitva Manalo sold her property in Quezon City to Transit Automotive Supply, receiving five PCI Bank checks as payment. She maintained deposit accounts with PCI Bank and Asian Bank. On June 26, 1992, she executed a Special Power of Attorney in favor of her niece, Veronidia Saturnino, authorizing Saturnino to collect rentals and other outstanding accounts due her and deposit them with authorized banks. Manalo then left for the United States, entrusting three of the five checks to Saturnino. The dispute arose from Saturnino's unauthorized withdrawal and misappropriation of the proceeds of those checks, facilitated by the acts and omissions of the three petitioner banks.

Primitiva Manalo sold her property at Timog, Quezon City to Transit Automotive Supply. As payment, Transit issued five PCI Bank checks payable to Manalo, dated June 10, 1992 through December 10, 1992, with amounts ranging from ₱1,265,000.00 to ₱7,235,000.00. On June 11, 1992, Manalo opened Savings Account No. 0903-20855-5 with PCI Bank and deposited the first two checks. On June 26, 1992, she executed a Special Power of Attorney in favor of her niece, Veronidia Saturnino, authorizing Saturnino to collect rentals and other outstanding accounts due her and deposit them with any authorized banks. Manalo then left for the United States, entrusting the remaining three checks — PCI Bank Check Nos. 315676, 315677, and 315678 — to Saturnino.

On August 10, 1992, Saturnino deposited PCI Bank Check No. 315676 (₱2,833,333.00) in Manalo's PCI Bank savings account. When cleared, ₱133,333.00 was maintained in the savings account while ₱2,600,000.00 was placed in Time Deposit Account No. 090-015344, maturing on September 14, 1992. On September 18, 1992, the time deposit proceeds of ₱2,618,195.53 were transferred to PCI GS Fund No. 086578, which was later rolled over until November 27, 1992, purportedly pursuant to Manalo's instructions. The fund, then amounting to ₱2,670,314.87, was pre-terminated upon Saturnino's instructions. PCI Bank issued Manager's Check No. 090 L-045694, a crossed check annotated "Payee's Account Only" with Manalo as indicated payee, and released it to Saturnino. Saturnino then handed the manager's check to Gensu Capital Management Corporation (GENSCOR) for investment. GENSCOR deposited it in its account with Premiere Bank, which accepted the deposit and credited the proceeds to GENSCOR's account.

On October 12, 1992, Saturnino deposited PCI Bank Check No. 315677 (₱2,833,333.00) in Asian Bank Savings Account No. SA-2016-12-00027-8 in Manalo's name. After clearance, ₱133,333.00 was kept in the savings account, ₱1,200,000.00 was placed in a Common Trust Fund, and ₱1,500,000.00 was deposited into an Asian Bank Capital Investment Corporation placement. On November 18, 1992, Asian Bank released the ABCIC placement proceeds of ₱1,519,609.34 to Saturnino by way of Asian Bank Manager's Check No. 001396 AP, a crossed check payable to Manalo. On March 31, 1993, the Common Trust Fund proceeds — ₱1,200,000.00 as principal and ₱71,453.59 as interest — were released to Saturnino by way of Manager's Check Nos. 001839 AP and 001840 AP, respectively, both crossed checks payable to Manalo. Saturnino invested Manager's Check Nos. 001396 AP and 001839 AP with GENSCOR, which deposited them in its Premiere Bank account; Premiere Bank accepted, cleared, and credited the proceeds to GENSCOR. Saturnino deposited Manager's Check No. 001840 AP in Manalo's Asian Bank savings account and withdrew the funds on May 14, 1993.

On December 17, 1992, Saturnino directly deposited PCI Bank Check No. 315678 (₱2,833,334.00) in GENSCOR's account with Premiere Bank as an investment. Premiere Bank accepted the deposit and credited the amount to GENSCOR's account. This check was a crossed check bearing the annotation "For Payee's Account Only."

In January 1995, Manalo returned to the Philippines and discovered that Saturnino had withdrawn the proceeds of PCI Bank Check Nos. 315676 and 315677 from PCI Bank and Asian Bank, respectively, and that PCI Bank Check No. 315678 had been deposited not in her account but to GENSCOR's account with Premiere Bank. Saturnino informed her there was a bank scam and promised to give her $20,000.00 for the time being. On March 31, 1995, Manalo filed a complaint for sum of money and damages, alleging that Saturnino misappropriated a total of ₱8,266,666.00 with the aid of the three banks. The RTC found that Saturnino's authority under the SPA was limited to depositing checks, not investing or withdrawing funds, and held the banks liable for negligence. The CA affirmed the RTC ruling in toto. Saturnino passed away in December 2000 and was substituted by her heirs; Manalo passed away on March 2, 2015 and was substituted by her surviving children.

• Asian Bank — Lack of Negligence: Asian Bank claimed it was not negligent in handling Manalo's accounts, relying on the SPA, Manalo's specimen signature cards, and withdrawal slips signed by Manalo.
• Asian Bank — Estoppel and Unjust Enrichment: Asian Bank contended that Manalo authorized the withdrawal of her placements and expressly allowed them to be invested in real estate property, thus estopping her from questioning Saturnino's authority. It posited that the principle of unjust enrichment bars Manalo from recovery.
• Asian Bank — Shifting Liability to Premiere Bank: Asian Bank argued that all manager's checks it issued were crossed checks payable to Manalo, and that Premiere Bank, as collecting bank, must suffer the loss for depositing them to GENSCOR's account. It stressed that Premiere Bank had the duty to ascertain the genuineness of all prior endorsements and was privy to the depositor who negotiated the checks.
• PCI Bank — SPA Authority: PCI Bank maintained that the SPA granted Saturnino authority to receive funds in Manalo's behalf from any person, corporation, or institution, whether in check or cash, which it interpreted as conferring power to receive funds deposited in Manalo's PCI Bank account.
• PCI Bank — Ratification: PCI Bank argued alternatively that even if Saturnino had no written authority to withdraw, Manalo ratified Saturnino's acts by authorizing the transfer of funds from savings to time deposit to trust fund accounts and allowing Saturnino to make withdrawals from time to time, thus estopping Manalo from questioning Saturnino's acts.
• PCI Bank — Proper Issuance of Crossed Check: PCI Bank asserted that it issued a crossed check payable only to Manalo and exercised the required diligence by ensuring only Manalo could benefit from the check. It denied liability, arguing it relied on Premiere Bank's express guarantee of the validity of all prior endorsements.
• PCI Bank — Shifting Liability: PCI Bank contended that Saturnino, GENSCOR, and Premiere Bank should be held liable to Manalo — Saturnino for failing to deliver the check to Manalo, and Premiere Bank for allowing the deposit to a non-payee account.
• Premiere Bank — Lack of Gross Negligence: Premiere Bank claimed it was not grossly negligent in allowing PCI Bank Check No. 315678 to be deposited to GENSCOR's account, asserting that the deposit took place after PCI Bank and Asian Bank recognized Saturnino's authority, influencing it to likewise recognize the SPA.
• Premiere Bank — Estoppel: Premiere Bank alleged that Saturnino was validly clothed with authority to deposit the subject check through an investment scheme with GENSCOR, that Manalo approved the investments and is estopped from claiming otherwise, and that Manalo's own negligence in managing her property should cause her to bear her own loss.
• Premiere Bank — Usual Accommodation: Premiere Bank disclaimed liability on PCI Bank Check Nos. 315676 and 315677, stating that by clearing said checks deposited to GENSCOR's account, it merely extended the usual accommodation observed by banks to investment firms. It contended that Manalo as payee was not prejudiced since ownership of the investment with GENSCOR still belonged to Manalo.
• Premiere Bank — Right of Reimbursement: Premiere Bank lamented that the RTC and CA failed to render judgment on Saturnino's liability to reimburse it and the other banks, and claimed entitlement to a judgment against GENSCOR based on its third-party complaint, urging that GENSCOR and Saturnino benefited from PCI Bank Check No. 315678.

• Banks' Gross Negligence: Manalo countered that Asian Bank and PCI Bank were grossly negligent in allowing Saturnino to withdraw the proceeds of PCI Bank Check Nos. 315676 and 315677. Although she conceded that Saturnino perpetrated the fraud, she emphasized that such fraud would not have been accomplished without the banks' reckless negligence.
• SPA Limitation: Manalo stressed that the SPA did not grant Saturnino authority to withdraw funds from her bank accounts.
• Premiere Bank's Wanton Negligence: Manalo accused Premiere Bank of wanton and inexcusable negligence in accepting and clearing the checks and depositing them to GENSCOR's account, pointing out that the breach of standard banking practice was not isolated but recurring, occurring on three separate occasions.
• Waiver of Right Against GENSCOR: Manalo contended that Premiere Bank impliedly waived its right to run after GENSCOR and the Heirs of Saturnino when it failed to raise such issue before the CA.
• Forgery Rule Inapplicable to PCI Bank: Manalo opposed PCI Bank's attempt to shift liability to Premiere Bank as collecting bank, urging that the assumption of liability by the collecting bank for its express warranty as last endorser applies only in cases of forgery. Since there were no claims that PCI Bank Check No. 315676 was forged, PCI Bank could not be absolved from its negligent act of allowing Saturnino to withdraw the proceeds sans proper authorization. She clarified that the issue was not the validity or genuineness of the check, but PCI Bank's negligence in clearing the manager's check despite knowledge of its nature and purpose.

• Negligence of Drawee Banks: Whether PCI Bank and Asian Bank were negligent in allowing Saturnino to withdraw Manalo's funds from her accounts without proper authority under the SPA.
• Negligence of Collecting Bank: Whether Premiere Bank was negligent in accepting and clearing crossed checks payable to Manalo and crediting them to GENSCOR's account.
• Apportionment of Liability: How liability should be apportioned among PCI Bank, Asian Bank, and Premiere Bank for the proceeds of the manager's checks issued by the drawee banks and cleared by the collecting bank.
• Premiere Bank's Liability for PCI Bank Check No. 315678: Whether Premiere Bank is solely liable to Manalo for the face value of PCI Bank Check No. 315678, which Saturnino directly deposited to GENSCOR's account with Premiere Bank.
• Right of Reimbursement: Whether the banks may recover from Saturnino, and whether Premiere Bank may recover from GENSCOR.
• Interest Rate: What interest rate should apply and from what date it should be reckoned.

• Negligence of Drawee Banks: Yes. PCI Bank and Asian Bank were negligent in allowing Saturnino to withdraw Manalo's funds, the SPA having granted only the authority to deposit, not to withdraw.
• Negligence of Collecting Bank: Yes. Premiere Bank was negligent in accepting and clearing crossed checks payable to Manalo and crediting them to GENSCOR's account, in breach of standard banking practice regarding crossed checks.
• Apportionment of Liability: Liability was apportioned fifty-fifty between the drawee banks and Premiere Bank for the manager's checks they respectively issued and cleared, based on their comparative negligence in setting the events in motion and perpetuating the fraud.
• Premiere Bank's Liability for PCI Bank Check No. 315678: Yes, Premiere Bank is solely liable. As the collecting bank that stamped its endorsement guaranteeing all prior indorsements on a crossed check bearing "For Payee's Account Only," it became a general endorser and cannot deny liability for the face value of the check.
• Right of Reimbursement: The banks may recover from Saturnino under the principle of unjust enrichment. Premiere Bank may no longer recover from GENSCOR, having failed to assert that right before the CA, thereby impliedly waiving it.
• Interest Rate: Twelve percent (12%) per annum from March 31, 1995 (date of judicial demand) until June 30, 2013, and six percent (6%) per annum from July 1, 2013 until full payment, pursuant to Nacar vs. Gallery Frames.

• Negligence of Drawee Banks: The fiduciary nature of banking requires high standards of integrity and performance, mandating banks to treat depositors' accounts with meticulous care and utmost fidelity. The SPA, strictly construed, granted Saturnino only the authority to collect rentals and other outstanding accounts related to Manalo's properties and deposit them in Manalo's bank accounts. There was nothing in the SPA that granted Saturnino authority to withdraw on Manalo's behalf. A special power to deposit funds does not include the authority to withdraw unless explicitly granted. The principle of ejusdem generis further restricted the general phrase "other accounts and collectibles" to rentals or accounts related to Manalo's properties. The proceeds of the manager's checks were not part of the receivable amounts Saturnino could collect under the SPA. PCI Bank's argument that the second enumerated power in the SPA conferred withdrawal authority was rejected under Article 1374 of the Civil Code, which requires interpreting stipulations together. The banks' reliance on the MOA and Summary of Investments as proof of ratification also failed: the MOA was not even presented to the banks before they allowed the withdrawals, the Summary of Investments was presented to Manalo years after the unauthorized withdrawals and was followed by her letter requesting investigation and her filing of a complaint, and the testimonies merely showed authorization to transfer funds between accounts, not to terminate placements and withdraw proceeds.

• Negligence of Collecting Bank: A crossed check — one with two parallel lines drawn across its face — has the legal effects that it may not be encashed but only deposited in the bank, may be negotiated only once to one who has an account with the bank, and serves as a warning to the holder that the check was issued for a definite purpose. The crossing of a check means it should be deposited only in the account of the payee. Premiere Bank never denied that the checks presented for deposit were crossed checks and admitted depositing them to GENSCOR's account pursuant to usual accommodation to investment firms. Its breach was not isolated but recurring, occurring on three separate occasions. As a banking institution, Premiere Bank was expected to know the legal significance of a crossed check.

• Apportionment of Liability: Under Article 1980 of the Civil Code, bank deposits are in the nature of simple loans or mutuum, creating a debtor-creditor relationship. Under Article 1953, payment made to the wrong party does not extinguish the obligation. Generally, the collecting bank is solely liable for the amount of the check it endorsed, except if the check was initially issued through negligence, as enunciated in Allied Banking Corporation vs. Lim Sio Wan and Bank of the Philippine Islands vs. Court of Appeals, where liability was apportioned between the drawee bank that negligently issued the check and the collecting bank that guaranteed, endorsed, and authorized payment to a person other than the payee. PCI Bank and Asian Bank set the events in motion by negligently issuing the manager's checks and handing them to Saturnino without proper authority from Manalo, while Premiere Bank perpetuated the fraud by accepting the crossed checks and crediting them to GENSCOR's account. A fifty-fifty apportionment was thus reasonable. However, Manager's Check No. 001840 AP (₱71,453.59) was not invested with GENSCOR but deposited by Saturnino to Manalo's Asian Bank savings account and subsequently withdrawn without authority; Asian Bank was therefore solely liable for that amount.

• Premiere Bank's Liability for PCI Bank Check No. 315678: Because Saturnino directly deposited PCI Bank Check No. 315678 to GENSCOR's account with Premiere Bank, a different rule of liability applied. The collecting bank or last endorser generally suffers the loss because it has the obligation to ascertain the genuineness of all prior indorsements and is privy to the depositor who negotiated the check. The law imposes on the collecting bank the duty to diligently scrutinize the check to determine its genuineness and regularity. The check bore the annotation "For Payee's Account Only," meaning the drawer intended it for deposit only by the payee, Manalo. Premiere Bank accommodated GENSCOR, accepted the crossed check, and stamped "all prior indorsements and/or lack of indorsements are guaranteed," thereby becoming a general endorser. Under Section 66 of the Negotiable Instruments Law, an endorser warrants that the instrument is genuine, that he has good title to it, that all prior parties had capacity to contract, and that the instrument is valid and subsisting at the time of endorsement. The Court approved direct action by the payee against the collecting bank, following Associated Bank vs. Court of Appeals, where the payee was allowed to recover directly from the collecting bank to abbreviate what would otherwise be a tedious process of sequential recovery. Although the cited cases involved forgeries of the payee's indorsement, the rule applies here because what matters is that the unauthorized payment stemmed from the wrongful deposit of the crossed check and the collecting bank's negligence in clearing it. Saturnino's unwarranted acts are akin to an unauthorized endorsement.

• Right of Reimbursement: The Court recognized that Saturnino authored the entire scheme leading to the misappropriation of Manalo's funds. Under Article 22 of the Civil Code, a person who acquires or comes into possession of something at the expense of another without just cause or legal ground shall return the same. The banks may recover from Saturnino under the principle of unjust enrichment, as recognized in Allied Banking Corporation vs. Lim Sio Wan and Metropolitan Bank and Trust Company vs. Philippine Bank of Communications. However, Premiere Bank may no longer recover from GENSCOR because the RTC denied its third-party complaint against GENSCOR, the CA did not rule on GENSCOR's liability, and Premiere Bank failed to assert its right against GENSCOR in its appeal before the CA, thereby impliedly waiving it. Raising the issue for the first time before the Supreme Court would violate GENSCOR's right to due process.

• Interest Rate: Following the guidelines in Nacar vs. Gallery Frames, when the obligation consists in the payment of money such as a loan or forbearance of money, the rate of interest in the absence of stipulation shall be twelve percent (12%) per annum computed from default, i.e., from judicial or extrajudicial demand until June 30, 2013, and thereafter six percent (6%) per annum until full payment. The amounts adjudged against the banks are subject to 12% per annum from March 31, 1995 (date of judicial demand) to June 30, 2013, and 6% per annum from July 1, 2013 until full payment.

• Fiduciary Nature of Banking — The banking business is imbued with public interest, and the fiduciary nature of banking requires high standards of integrity and performance. Banks are mandated to treat the accounts of their depositors with meticulous care and utmost fidelity. This high standard of care is deemed written into every deposit agreement. Applied here, PCI Bank and Asian Bank were bound to treat Manalo's deposits with utmost fidelity but were remiss in allowing Saturnino to withdraw Manalo's funds without proper authority.

• Strict Construction of Powers of Attorney — A power of attorney must be strictly construed and pursued. Where powers and duties are specified and defined in an instrument, said powers are confined to those expressly stated, and all other powers are excluded. The agent may not go beyond or deviate from the power of attorney. A special power to deposit funds does not include the authority to withdraw funds unless explicitly granted or stated. The act of withdrawal is one of special dominion requiring special authority.

• Ejusdem Generis — Where a general word or phrase follows an enumeration of particular and specific words of the same class, the general word or phrase is to be construed to include, or be restricted to, things akin to or resembling, or of the same kind or class as, those specifically mentioned. Applied here, the general phrase "other accounts and collectibles" in the SPA was restricted to rentals or accounts related to Manalo's properties.

• Effects of a Crossed Check — A crossed check has the following legal effects: (i) the check may not be encashed but only deposited in the bank; (ii) the check may be negotiated only once to one who has an account with the bank; and (iii) the act of crossing the check serves as a warning to the holder that the check has been issued for a definite purpose and he must inquire if he received the check pursuant to this purpose; otherwise, he is not a holder in due course. The crossing of a check means it should be deposited only in the account of the payee.

• Collecting Bank Liability as General Endorser — The collecting bank or last endorser generally suffers the loss because it has the obligation to ascertain the genuineness of all prior indorsements and is privy to the depositor who negotiated the check. By stamping "all prior indorsements and/or lack of indorsements guaranteed," the collecting bank becomes a general endorser warranting under Section 66 of the Negotiable Instruments Law that the instrument is genuine, that it has good title, that all prior parties had capacity to contract, and that the instrument is valid and subsisting at the time of endorsement.

• Direct Action by Payee Against Collecting Bank — The payee of crossed checks may go directly against the collecting bank to abbreviate and simplify what would otherwise be a tedious process of sequential recovery. This applies not only in cases of forged endorsements but whenever the unauthorized payment stems from the wrongful deposit of a crossed check and the negligence of the collecting bank in clearing it, provided the payee did not receive the proceeds due to the fraud or maneuvering of third persons.

• Comparative Negligence in Bank Liability — Generally, the collecting bank is solely liable for the amount of the check it endorsed, except if the check was initially issued through negligence. In such cases, liability is apportioned between the drawee bank that negligently issued the check and the collecting bank that guaranteed, endorsed, and authorized payment to a person other than the payee.

• Bank Deposit as Mutuum — Under Article 1980 of the Civil Code, fixed, savings, and current deposits of money in banks are governed by the provisions concerning simple loan. The relationship between a bank and its depositor is one of debtor-creditor. Payment made by the debtor to the wrong party does not extinguish the obligation to the creditor, even if made in good faith or through fraud by a third person.

• Unjust Enrichment — Under Article 22 of the Civil Code, every person who through an act or performance by another acquires or comes into possession of something at the expense of the latter without just cause or legal ground shall return the same. Banks held liable for negligence may recover from the party who authored the fraud and ultimately benefited from the unlawful transaction.

• "The fiduciary nature of banking requires banks to perform their duties with extraordinary care and utmost diligence. Thus, a drawee bank who negligently allows an unauthorized withdrawal from its depositor's account shall be ordered to return the lost funds. In the same vein, a collecting bank who heedlessly endorses and clears a crossed check, shall be liable for its face value." — This is the opening statement of the decision, encapsulating the core ruling on the respective liabilities of drawee and collecting banks.

• "Verily, there is nothing in the SPA that granted Saturnino authority to withdraw on Manalo's behalf. Rather, Saturnino was only authorized to collect rentals and other outstanding obligations related to Manalo's properties, and deposit them in the latter's bank accounts. Allowing Saturnino to withdraw Manalo's funds would be enlarging the scope of her powers, which was never intended or specified by the parties." — This passage articulates the ratio decidendi on the strict construction of the SPA and the absence of withdrawal authority.

• "To stress, a crossed check is one where two parallel lines are drawn across its face. Legally, it has the following effects, (i) the check may not be encashed but only deposited in the bank; (ii) the check may be negotiated only once to the one who has an account with the bank; and (iii) the act of crossing the check serves as a warning to the holder that the check has been issued for a definite purpose and he must inquire if he received the check pursuant to this purpose; otherwise, he is not a holder in due course." — This is the canonical formulation of the legal effects of a crossed check, frequently cited in banking law jurisprudence.

• "Concededly, the cases cited involved forgeries of the payee's indorsement. However, the rule granting the payee direct recourse against the collecting bank applies to the case at bar. What matters is that the unauthorized payment ultimately stemmed from the wrongful deposit of the crossed check, and the negligence of the collecting bank in clearing said check." — This passage extends the doctrine of direct payee recourse against the collecting bank beyond forgery cases to situations involving unauthorized deposit of crossed checks.

• Allied Banking Corporation vs. Lim Sio Wan, et al., 573 Phil. 89 (2008) — Controlling precedent on apportionment of liability between drawee and collecting banks when a check is issued through negligence and cleared by the collecting bank. Also recognized the right of reimbursement against parties who ultimately benefited from the unlawful transaction.
• Bank of the Philippine Islands vs. Court of Appeals, 290 Phil. 452 (1992) — Followed on the apportionment of liability between negligent drawee and collecting banks.
• Associated Bank vs. Court of Appeals, 284 Phil. 615 (1992) — Controlling precedent allowing the payee to go directly against the collecting bank to abbreviate the process of sequential recovery. Extensively quoted for the principle that the collecting bank's failure to inquire into the authority of the endorser constitutes a breach of duty.
• Metropolitan Bank and Trust Co. vs. Philippine Bank of Communications, 562 Phil. 511 (2007) — Followed on the collecting bank's duty to diligently scrutinize checks and its right to recover from persons who caused the fraud.
• Metropolitan Bank and Trust Co. (formerly Asianbank Corp.) vs. BA Finance Corp., et al., 622 Phil. 637 (2009) — Cited as precedent affirming the payee's right to go after the collecting bank for unauthorized payment of checks.
• Westmont Bank vs. Ong, 425 Phil. 836 (2002) — Cited as precedent affirming the payee's right to go after the collecting bank for unauthorized payment of checks.
• Asia Brewery, et al. vs. Equitable PCI Bank, 809 Phil. 289 (2017) — Cited as precedent affirming the payee's right to go after the collecting bank for unauthorized payment of checks.
• Nacar vs. Gallery Frames, 716 Phil. 267 (2013) — Controlling precedent on the applicable legal interest rates: 12% per annum from default until June 30, 2013, and 6% per annum thereafter until full payment.
• BDO vs. Lao, 811 Phil. 280 (2017) — Followed on the imposition of 12% interest from date of judicial demand until June 30, 2013, and 6% interest from July 1, 2013 until full satisfaction.
• Mercado vs. Allied Banking Corporation, 555 Phil. 411 (2007) — Followed on the strict construction of powers of attorney.
• Philippine National Bank vs. Pike, 507 Phil. 322 (2005) — Cited for the fiduciary nature of banking and the high standard of care owed to depositors.

• Article 1980, Civil Code — Provides that fixed, savings, and current deposits of money in banks shall be governed by the provisions concerning simple loan. Applied to establish that the bank-depositor relationship is one of debtor-creditor, and that payment to the wrong party does not extinguish the bank's obligation to the depositor.
• Article 1953, Civil Code — Provides that a person who receives a loan of money or any other fungible thing acquires ownership thereof and is bound to pay the creditor an equal amount of the same kind and quality. Applied to the bank's obligation to return funds improperly withdrawn.
• Article 22, Civil Code — Provides that every person who through an act or performance by another acquires or comes into possession of something at the expense of the latter without just cause or legal ground shall return the same. Applied to grant the banks the right of reimbursement against Saturnino.
• Article 1374, Civil Code — Provides that the various stipulations of a contract shall be interpreted together, attributing to doubtful ones that sense which may result from all of them taken jointly. Applied in construing the SPA to determine that Saturnino's authority was limited to collecting rentals and depositing funds.
• Section 66, Negotiable Instruments Law — Provides that an endorser warrants that the instrument is genuine, that he has good title to it, that all prior parties had capacity to contract, and that the instrument is valid and subsisting at the time of endorsement. Applied to hold Premiere Bank liable as a general endorser for the face value of PCI Bank Check No. 315678.
• Section 2, Republic Act No. 8791 (General Banking Law of 2000) — States the fiduciary nature of banking and the requirement for high standards of integrity and performance. Applied to establish the standard of care owed by banks to their depositors.

Perlas-Bernabe, S.A.J. (Chairperson), Hernando, Inting, and Dimaampao, JJ., concurred.