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METROPOLITAN BANK v. CA

FACTS:

This case involves a dispute between Metropolitan Bank & Trust Company (Metrobank) and United Overseas Bank (UOB) regarding a check that was deposited with UOB. The check was drawn against the account of Bienvenido C. Tan with Metrobank and was sent for clearing through the Philippine Clearing House Corporation (PCHC). Metrobank notified UOB that it was returning the check due to material alterations, specifically changes in the date and amount. However, UOB refused to accept the return and reimburse Metrobank. As a result, Metrobank lodged a complaint with the PCHC Arbitration Committee, arguing that UOB had failed to exercise due diligence in examining the check for any alterations. UOB countered that it had indeed exercised due diligence and that Metrobank had cleared the check with gross negligence.

The Arbitration Committee ordered Metrobank to submit the check for examination at the Philippine National Police (PNP) Crime Laboratory. However, Metrobank requested multiple postponements of the hearings due to the unavailability of the examination results. Eventually, when Metrobank's counsel failed to appear at a hearing, UOB moved for the dismissal of the case, which the Arbitration Committee granted.

Upon receiving the examination results, Metrobank filed a motion for reconsideration, but it was denied. Undeterred, Metrobank filed a second motion for reconsideration, which was also denied. The PCHC Board of Directors subsequently issued a resolution denying the second motion for reconsideration. Unsatisfied with the outcome, Metrobank filed a petition for review with the Regional Trial Court (RTC) of Makati City. Nonetheless, the RTC dismissed the petition, citing issues of jurisdiction and untimeliness.

ISSUES:

  1. Whether the trial court had jurisdiction over the petition for review filed by Metrobank.

  2. Whether Metrobank's claim against UOB can be sustained.

RULING:

  1. The trial court ruled that it had no jurisdiction over the petition since it was filed out of time. The Court of Appeals affirmed this ruling.

  2. The trial court also ruled that Metrobank's claim could not be sustained. This ruling was also affirmed by the Court of Appeals.

PRINCIPLES:

  • The drawee-bank should bear the loss if it had mistakenly cleared a forged or altered check.

  • A petition for review should be filed within the prescriptive period stated in the rules of procedure.