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    Co-Ownership Ong Tan v. Rodriguez GR 230404 January 31, 2018 1 Division: Tijam, J

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    April John Latorza
    This case involves a dispute over ownership of funds in a joint bank account between Ong Tan and the Rodriguez siblings. The Supreme Court ruled that Tan exclusively owns the funds. It found that while joint accounts presumptively have equal shares, Tan presented evidence to overcome this presumption by showing the funds came solely from her separate bank account. Specifically, Tan submitted documents tracing the exact amount deposited in the joint account from her personal funds. Therefore, the Court awarded full ownership of the funds to Tan.

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    Co-Ownership Ong Tan v. Rodriguez GR 230404 January 31, 2018 1 Division: Tijam, J

    Uploaded by

    April John Latorza
    35 views2 pages
    This case involves a dispute over ownership of funds in a joint bank account between Ong Tan and the Rodriguez siblings. The Supreme Court ruled that Tan exclusively owns the funds. It found that while joint accounts presumptively have equal shares, Tan presented evidence to overcome this presumption by showing the funds came solely from her separate bank account. Specifically, Tan submitted documents tracing the exact amount deposited in the joint account from her personal funds. Therefore, the Court awarded full ownership of the funds to Tan.

    Original Description:

    Article 485 of the Civil Coe

    Original Title

    Ong-Tan-v.-Rodriguez

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    This case involves a dispute over ownership of funds in a joint bank account between Ong Tan and the Rodriguez siblings. The Supreme Court ruled that Tan exclusively owns the funds. It found that while joint accounts presumptively have equal shares, Tan presented evidence to overcome this presumption by showing the funds came solely from her separate bank account. Specifically, Tan submitted documents tracing the exact amount deposited in the joint account from her personal funds. Therefore, the Court awarded full ownership of the funds to Tan.

    Copyright:

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

    Co-Ownership Ong Tan v. Rodriguez GR 230404 January 31, 2018 1 Division: Tijam, J

    Uploaded by

    April John Latorza
    This case involves a dispute over ownership of funds in a joint bank account between Ong Tan and the Rodriguez siblings. The Supreme Court ruled that Tan exclusively owns the funds. It found that while joint accounts presumptively have equal shares, Tan presented evidence to overcome this presumption by showing the funds came solely from her separate bank account. Specifically, Tan submitted documents tracing the exact amount deposited in the joint account from her personal funds. Therefore, the Court awarded full ownership of the funds to Tan.

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    © All Rights Reserved
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    Co-ownership  The nature of joint accounts is

    Ong Tan v. Rodriguez governed by the rule on co-ownership


    GR 230404; January 31, 2018 embodied in Article 485 of the Civil
    1st Division: Tijam, J: Code.
     A joint account is one that is held
     The RODRIGUEZ SIBLINGS were the jointly by two or more natural persons
    surviving children of the deceased or by two or more juridical persons or
    Reynaldo and Ester Rodriguez. entities. Under such setup, the
     TAN was the co-depositor of Reynaldo depositors are joint owners or co-
    in a Joint Account in the Bank of the owners of the said account, and their
    Philippine Islands (BPI). share in the deposits shall be
     TAN wanted to withdraw the funds presumed equal unless the contrary is
    from the joint account. proved. 
     However, BPI required her to submit
    additional requirements, one of which Issue:
    is the extrajudicial settlement of the Who owns the funds in the joint account?
    heirs of Reynaldo. 
     TAN asked the RODRIGUEZ SIBLINGS Held:
    to sign a waiver of rights to the said  TAN owns the funds exclusively in the
    joint account. joint account.
     The RODRIGUEZ SIBLINGS refused to  TAN overturned the presumption of
    sign the waiver, alleging that the funds equal shares by presenting evidence
    in the said joint account belonged to to the contrary.
    their father, Reynaldo.   The following rules are to be
     TAN alleged that the funds used to considered in treating the shares of
    open the BPI joint account were her joint account holders.
    exclusive funds from her East West  General rule: the shares of the
    Bank (East West) account. owners of the joint account
     TAN presented the following: holders are presumed equal.
     A Debit Memo from East West  Exceptions:
    Bank, which was used to issue a 1. The existence of survivorship
    Manager's Check in the amount of agreement between the co-
    ₱1,021,868.30, which exact depositors.
    amount was deposited to the BPI 2. By presenting evidence to the
    joint account.  contrary, which shows their
     The testimony of the Branch respective shares.
    Manager of East West to  Here, there was no survivorship
    corroborate her testimony that agreement between TAN and
    the subject amount came from her Reynaldo.
    East West account.   However, TAN’s evidence sufficiently
    proved that she exclusively owns the
    Issue: funds in the BPI joint account.
    What governs the nature of joint  The Supreme Court also took note that
    accounts? the RODRIGUEZ SIBLINGS admitted
    that they knew about the existence of
    Held:
    the joint account yet, they still failed to
    include the same in the listed
    properties in the inventory when they
    executed an extrajudicial settlement.
    Their failure refutes their claim that
    Reynaldo was the sole owner of the
    funds in the said joint account.

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