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FAR EAST BANK v. ESTRELLA O. QUERIMIT

FACTS:

Far East Bank and Trust Company (FEBTC) is the petitioner in this case, while Estrella O. Querimit is the respondent. Respondent, who worked as an internal auditor of the Philippine Savings Bank, opened a dollar savings account with FEBTC in 1986. She was issued four Certificates of Deposit amounting to $60,000, which were to mature in 60 days and would earn interest if not encashed or pre-terminated. The bank assured respondent that her deposit would earn interest upon maturity even without surrendering the certificates. In 1989, respondent used her savings in another bank to cover her husband's medical expenses.

In 1993, respondent returned to the Philippines and attempted to withdraw her deposit from FEBTC, only to be informed that her husband had already withdrawn the funds. Consequently, respondent filed a complaint against FEBTC, its branch manager, and its president. FEBTC claimed that it accommodated respondent's husband in withdrawing the deposit and provided documents to support this claim.

The trial court ruled in favor of respondent, ordering FEBTC to allow her to withdraw her deposit and awarding damages and attorney's fees. FEBTC appealed to the Court of Appeals, which affirmed the trial court's decision but modified it to state that the individual defendants were not solidarily liable with FEBTC. Unsatisfied with the decision, FEBTC now appeals to the Supreme Court.

The main issue in this case is whether the certificates of deposit have been paid by FEBTC.

ISSUES:

  1. Whether the subject certificates of deposit have already been paid by petitioner.

RULING:

  1. The Court of Appeals affirmed the decision of the trial court, ordering petitioner Far East Bank and Trust Co. (FEBTC) to allow respondent Estrella O. Querimit to withdraw her time deposit with FEBTC. The appeals court held that FEBTC failed to prove that the certificates of deposit had been paid out of its funds. However, the individual defendants, Edgardo F. Blanco and Octavio Espiritu, were not held solidarily liable with FEBTC as they have a separate personality from the bank.

PRINCIPLES:

  • The bank has the burden of proving that payments have been made on the certificates of deposit.

  • Officers and stockholders of a bank are not solidarily liable with the bank itself.