FACTS:

This case involves a dispute over a joint account in the Bank of the Philippine Islands (BPI) between Anita Ong Tan and Reynaldo Rodriguez. Reynaldo and his wife Ester passed away in 2008 and 2004 respectively, leaving several properties to their children. On February 13, 2009, the children executed an Extrajudicial Settlement of the Estate of Reynaldo and Ester.

Anita, a co-depositor in the joint account, received a letter from BPI stating that the account would become dormant if no transaction was made. Anita decided to withdraw her funds but was required by BPI to submit additional requirements, including the extrajudicial settlement of Reynaldo's heirs. Anita asked the children to sign a waiver of rights to the joint account, but they refused, believing that the funds belonged to their father.

The children then submitted documents to BPI to release half of the funds in the joint account. However, BPI withheld the release due to the conflicting claims between Anita and the children. Anita filed a petition for the settlement of Reynaldo's intestate estate and the issuance of letters of administration to a neutral person.

Anita claimed that the funds used to open the joint account were her exclusive funds, which came from her account in East West Bank. She presented a Debit Memo from East West Bank and the testimony of Mineleo Serrano, Branch Manager of East West in Tomas Morato, to support her claim. The children filed a motion to dismiss, arguing that the funds belonged exclusively to Reynaldo.

The trial court ruled in favor of Anita, stating that she sufficiently provided evidence to rebut the presumption that the funds in the joint account were owned by Anita and Reynaldo in common. The court ordered the withdrawal of funds and their release to Anita. The children appealed to the Court of Appeals (CA), which reversed the trial court's ruling. The CA held that Anita failed to prove that she was the sole owner of the funds. The CA ordered the division of the funds equally between Anita and the children. Anita's motion for reconsideration was denied, leading her to file a Petition for Review on Certiorari before the Supreme Court.

ISSUES:

1. Whether or not the Court of Appeals (CA) erred in declaring Anita and Reynaldo as co-owners of the subject bank deposits despite the evidence submitted by Anita to prove otherwise.

RULING:

1. The Supreme Court held that the CA did not err in declaring Anita and Reynaldo as co-owners of the subject bank deposits. A joint account is one that is held jointly by two or more natural persons, and the depositors are joint owners or co-owners of the account. The share in the deposits is presumed to be equal, unless the contrary is proved. In this case, Anita failed to prove that she is the sole owner of the funds in the joint account. Thus, the CA's ruling that the bank deposits should be divided equally between Anita and the respondents was affirmed.

PRINCIPLES:

• A joint account is held jointly by two or more individuals, and the depositors are considered joint owners or co-owners of the account.

• The share in the deposits of a joint account is presumed to be equal, unless the contrary is proved.

• A stipulation in a contract contrary to the proportional share of co-owners as stated in the Civil Code is void.