Facts: Petitioner Metrobank Is A Domestic Banking Corporation Duly Organized and Existing Under The

FACTS:
Petitioner Metrobank is a domestic banking corporation duly organized and existing under the
laws of the Philippines. Respondent Rosales is the owner of a travel agency while Yo Yuk To is her mother.
In 2000, respondents opened a Joint Peso Account10 with petitioner’s Pritil-Tondo Branch.
In May 2002, respondent Rosales accompanied her client Liu Chiu Fang, a Taiwanese National
applying for a retiree’s visa from the Philippine Leisure and Retirement Authority (PLRA), to petitioner’s
branch in Escolta to open a savings account. Since Liu Chiu Fang could speak only in Mandarin, respondent
Rosales acted as an interpreter for her.
On March 3, 2003, respondents opened with petitioner’s Pritil-Tondo Branch a Joint

Dollar Account with an initial deposit of US$14,000.00.
On July 31, 2003, petitioner issued a “Hold Out” order against respondents’ accounts.
On September 3, 2003, petitioner, through its Special Audit Department Head Antonio
Ivan Aguirre, filed before the Office of the Prosecutor of Manila a criminal case for Estafa through False
Pretences, Misrepresentation, Deceit, and Use of Falsified Documents.
Respondent Rosales, however, denied taking part in the fraudulent and unauthorized withdrawal
from the dollar account of Liu Chiu Fang.
On December 15, 2003, the Office of the City Prosecutor of Manila issued a Resolution
dismissing the criminal case for lack of probable cause. On September 10, 2004, respondents filed before
the RTC of Manila a complaint for Breach of Obligation and Contract with Damages.
ISSUE:
Whether Metrobank breached its contract with respondents.
HELD:
YES. The Court held that Metrobank’s reliance on the “Hold Out” clause in the Application and
Agreement for Deposit Account is misplaced.
Bank deposits, which are in the nature of a simple loan or mutuum, must be paid upon demand
by the depositor.
The “Hold Out” clause applies only if there is a valid and existing obligation arising from any of
the sources of obligation enumerated in Article 1157 of the Civil Code, to wit: law, contracts, quasi-
contracts, delict, and quasi-delict. In this case, petitioner failed to show that respondents have an obligation
to it under any law, contract, quasi-contract, delict, or quasi-delict. And although a criminal case was filed
by petitioner against respondent Rosales, this is not enough reason for petitioner to issue a “Hold Out” order
as the case is still pending and no final judgment of conviction has been rendered against respondent
Rosales.
In fact, it is significant to note that at the time petitioner issued the “Hold Out” order, the criminal
complaint had not yet been filed. Thus, considering that respondent Rosales is not liable under any of the
five sources of obligation, there was no legal basis for petitioner to issue the “Hold Out” order. Accordingly,
we agree with the findings of the RTC and the CA that the “Hold Out” clause does not apply in the instant
case.
In view of the foregoing, the Court found that petitioner is guilty of breach of contract when it
unjustifiably refused to release respondents’ deposit despite demand. Having breached its contract with
respondents, petitioner is liable for damages.
PELAYO VS. LAURON Case Digest

ARTURO PELAYO VS. MARCELO LAURON
12 Phil 453
January 12, 1909
FACTS: On November 23, 1906, Arturo Pelayo, a physician, filed a complaint against Marcelo and
Juana Abella. He alleged that on October 13, 1906 at night, Pelayo was called to the house of the
defendants to assist their daughter-in-law who was about to give birth to a child. Unfortunately, the
daughter-in-law died as a consequence of said childbirth. Thus, the defendant refuses to pay. The
defendants argue that their daughter-in-law lived with her husband independently and in a separate
house without any relation, that her stay there was accidental and due to fortuitous event.
ISSUE: Whether or not the defendants should be held liable for the fees demanded by the plaintiff
upon rendering medical assistance to the defendants’ daughter-in-law.
RULING: No. The Court held that the rendering of medical assistance is one of the obligations to
which spouses are bound by mutual support, expressly determined by law and readily demanded.
Therefore, there was no obligation on the part of the in-laws but rather on the part of the husband who
is not a party.
Thus, decision affirmed.
FACTS:
Two lots owned by Belen Aldaba are being disputed in this case. Petitoners Dr. Vicente Aldaba and Jane
Aldaba, father and daughter, lived with Belen Aldaba for 10 years and took care of her until her death. Belen
had presumptive heirs her surviving husband Estanislao Bautista, and her brother Cesar Aldaba (represented
as the respondents in this case.) After the death of Belen, the respondents asked the petitioners to leave the
premises and upon their refusal, the former instituted an ejectment case. The petitioners argue that Belen
really intended to donate the property to them as evidence by the note written by Belen to them which
reads, ―Huag kayong umalis diyan. Talagang iyan ay para sa inyo. Alam nila na iyan ay sa inyo.‖ They also
argue that the property was for compensation of their services which amounted to P53,000. The
respondents contend that the letter no way proves a donation.
ISSUE:
Whether or not there was a disposition of property by Belen in favour of the petitioners?
RULING: NO
For the following reasons: (1) The note was insufficient conveyance, and hence could not be considered as
evidence of a donation with onerous caus. The note can be considered, at most, as indicative of the intention
to donate. (2) no notarial document was executed by Belen to the petitioners during those 10 years. (3)
P53,000 worth of services made by the petitioners no way proves the alleged donation. If at all, the
petitioners believed that the gratuitous use of the property was not sufficient to compensate them for their
services, they could have presented their claims in the intestate proceedings, which they themselves could
have initiated, if none was instituted.
The SC emphasized that there was no express agreement between the parties and that respondents Jane
did not even expect to be compensated.

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FACTS:

On March 3, 2003, respondents opened with petitioner’s Pritil-Tondo Branch a Joint

Whether Metrobank breached its contract with respondents.

PELAYO VS. LAURON Case Digest

Thus, decision affirmed.

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