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    Citystate Savings Bank V Tobias

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    Burnok Supol
    This case involves Citystate Savings Bank's liability for the misappropriation of funds by its former branch manager Rolando Robles. Robles persuaded respondent Teresita Tobias to invest over PHP 1.8 million in the bank's back-to-back scheme, promising high returns. However, Robles later withdrew the money for personal use. The court ruled that the bank is liable under the doctrine of apparent authority as Robles, as branch manager, had apparent authority to act for the bank in facilitating banking transactions based on his position and the bank's practices. While Robles' actions directly caused the loss, the bank allowed him to act with full authority and is therefore solidarity liable with Robles for damages.

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    © All Rights Reserved
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    Citystate Savings Bank V Tobias

    Uploaded by

    Burnok Supol
    169 views2 pages
    This case involves Citystate Savings Bank's liability for the misappropriation of funds by its former branch manager Rolando Robles. Robles persuaded respondent Teresita Tobias to invest over PHP 1.8 million in the bank's back-to-back scheme, promising high returns. However, Robles later withdrew the money for personal use. The court ruled that the bank is liable under the doctrine of apparent authority as Robles, as branch manager, had apparent authority to act for the bank in facilitating banking transactions based on his position and the bank's practices. While Robles' actions directly caused the loss, the bank allowed him to act with full authority and is therefore solidarity liable with Robles for damages.

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    Civrev digest

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    Citystate Savings Bank v Tobias

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    This case involves Citystate Savings Bank's liability for the misappropriation of funds by its former branch manager Rolando Robles. Robles persuaded respondent Teresita Tobias to invest over PHP 1.8 million in the bank's back-to-back scheme, promising high returns. However, Robles later withdrew the money for personal use. The court ruled that the bank is liable under the doctrine of apparent authority as Robles, as branch manager, had apparent authority to act for the bank in facilitating banking transactions based on his position and the bank's practices. While Robles' actions directly caused the loss, the bank allowed him to act with full authority and is therefore solidarity liable with Robles for damages.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    169 views2 pages

    Citystate Savings Bank V Tobias

    Uploaded by

    Burnok Supol
    This case involves Citystate Savings Bank's liability for the misappropriation of funds by its former branch manager Rolando Robles. Robles persuaded respondent Teresita Tobias to invest over PHP 1.8 million in the bank's back-to-back scheme, promising high returns. However, Robles later withdrew the money for personal use. The court ruled that the bank is liable under the doctrine of apparent authority as Robles, as branch manager, had apparent authority to act for the bank in facilitating banking transactions based on his position and the bank's practices. While Robles' actions directly caused the loss, the bank allowed him to act with full authority and is therefore solidarity liable with Robles for damages.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
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    Title: Citystate Savings Bank V.

    Teresita Tobias And Shellidie Valdez


    G.R. No. 227990 Date: March 07, 2018 Ponente: REYES, Jr, J.
    Subject: CivRev
    Nature of the Action:
     Rolando Robles (hereinafter referred to as Robles), a certified public accountant, has been
    employed with Citystate Savings Bank (hereinafter referred to as the petitioner) since July
    1998 then as Accountanttrainee for its Chino Roces Branch. On September 6, 2000, Robles
    was promoted as acting manager for petitioner's Baliuag, Bulacan branch, and eventually
    as manager.
     Sometime in 2002, respondent Teresita Tobias (hereinafter referred to as Tobias), a meat
    vendor at the Baliuag Public Market, was introduced by her youngest son to Robles, branch
    manager of petitioner's Baliuag, Bulacan branch.
     Robies persuaded Tobias to open an account with the petitioner, and thereafter to place
    her money in some high interest rate mechanism, to which the latter yielded
     Thereafter, Robies would frequent Tobias' stall at the public market to deliver the interest
    earned by her deposit accounts in the amount of Php 2,000.00. In turn, Tobias would hand
    over her passbook to Robies for updating. The passbook would be returned the following
    day with typewritten entries but without the corresponding counter signatures.
     Tobias was later offered by Robies to sign-up in petitioner's back-to-back scheme which is
    supposedly offered only to petitioner's most valued clients. Under the scheme, the
    depositors authorize the bank to use their bank deposits and invest the same in different
    business ventures that yield high interest. Robies allegedly promised that the interest
    previously earned by Tobias would be doubled and assured her that he will do all the paper
    work. Lured by the attractive offer, Tobias signed the pertinent documents without reading
    its contents and invested a total of Php 1,800,000.00 to petitioner through Robies. Later,
    Tobias became sickly, thus she included her daughter and herein respondent Shellidie
    Valdez (hereinafter referred to as Valdez), as co-depositor in her accounts with the
    petitioner.
     In 2005, Robies failed to remit to respondents the interest as scheduled. Respondents tried
    to reach Robies but he can no longer be found; their calls were also left unanswered. In a
    meeting with Robies' siblings, it was disclosed to the respondents that Robies withdrew the
    money and appropriated it for personal use. Robies later talked to the respondents,
    promised that he would return the money by installments and pleaded that they do not
    report the incident to the petitioner. Robies however reneged on his promise. Petitioner
    also refused to make arrangements for the return of respondents' money despite several
    demands.
    Issues:
    WON Petitioner is liable under THE DOCTRINE OF APPARENT AUTHORITY
    Ruling:

    YES. Nonetheless, while it is clear that the proximate cause of respondents' loss is the
    misappropriation of Robles, petitioner is still liable under Article 1911 of the Civil Code, to wit:
    Art. 1911. Even when the agent has exceeded his authority, the principal is solidarity liable with
    the agent if the former allowed the latter to act as though he had full powers.
    The existence of apparent or implied authority is measured by previous acts that have been
    ratified or approved or where the accruing benefits have been accepted by the principal. It
    may also be established by proof of the course of business, usages and practices of the bank;
    or knowledge that the bank or its officials have, or is presumed to have of its responsible
    officers' acts regarding bank branch affairs.

    As aptly pointed by the CA, petitioner's evidence bolsters the case against it, as they support
    the finding that Robles as branch manager, has been vested with the apparent or implied
    authority to act for the petitioner in offering and facilitating banking transactions.

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