DOCTRINE / TICKLER: LIABILITY OF BANK TO 3RD PERSONS FOR ACTS DONE BY

ITS EMPLOYEES LIMIITED TO ACTS PERFORMED WITHIN THE SCOPE OF

APPARENT AUTHORITY WHICH THE BANK VESTED
CITY STATE SAVINGS BANK vs. TERESITA TOBIAS and SHELLIDIE VALDEZ
G.R. No. 227990; MARCH 7, 2018
REYES, JR., j.

FACTS: Rolando Robles was the branch manager of the Baliuag, Bulacan branch of
Citystate Savings Bank (CSB). Robles was introduced to Teresita Tobias, a meat vendor
at the Baliuag Public Market, by the latter’s youngest son.
Robles was able to persuade Tobias to open an account with CSB and to place her money
in some high interest rate mechanism. Thereafter, he would frequent Tobias’ stall at the
public market to deliver the interest earned by her deposit accounts which amounted to
Php 2,000. Tobias would then turnover the passbook to Robles for updating. The
passbook was returned the following day with typewritten entries, but without the
corresponding counter signatures.
Robles later offered Tobias to sign-up in CSB’s back-to-back scheme which is supposedly
offered only to the bank’s most valued clients. Under this scheme, the depositors authorize
the bank to use their bank deposits and invest the same in different business ventures that
yield high interest. Robles assured Tobias that the interest she previously earned would
be doubled, so the latter signed the pertinent documents without readings its contents and
invested a total of Php 1,800,000.
When Tobias became sickly, she included her daughter and Shellidie Valdez as co-
depositor in her accounts with CSB. Unfortunately, Robles failed to remit to Tobias and
Valdez the interest as scheduled. They tried to reach Robles, but he cannot be found
anymore. The siblings of Robles disclosed to them that Robles withdrew the money and
appropriated the money for his personal use.
Robles promised to return the money by installments, but he failed to comply with his
promise. CSB also refused to make arrangements for the return of Tobias’ money despite
several demands.
A complaint for sum of money was filed against Robles and CSB alleging that Robles
committed fraud in the performance of duties as branch manager when he lured Tobias in
signing several pieces of blank documents under the assurance, as bank manager of CSB,
that everything was in order.
The RTC ordered Robles to pay Tobias the sum of money and absolved the bank of any
liability. However, the CA reversed the decision of the lower court and ruled that CSB and
Robles are jointly and severally liable to pay Tobias the sum of money set forth. CSB
denied its liability by arguing that Robles acted in his personal capacity in dealing with
Tobias, who agreed with full knowledge and consent to the back-to-back loans and it was
not privy to the transactions between them. CSB also alleged that the doctrine of apparent
authority is not applicable in this case.
ISSUE: Whether or not CSB can be held liable for the transactions entered into by Robles,
as its bank manager, with Tobias, as depositor?
HELD: YES, CSB is solidarily liable to Tobias and Valdez for the damages caused by the
acts of Robles as its employer.
The bank, in its capacity as principal, may be liable under the doctrine of apparent authority
wherein its liability is solidary with that of his employee. Under the said doctrine, it imposes
liability because of the actions of a principal or an employer in somehow misleading the
public into believing that the relationship or the authority exists. The liability of a bank to
3rd persons for acts done by its agents or employees is limited to the consequences of the
latter’s acts which it has ratified, or those that resulted in the performance of acts within
the scope of actual or apparent authority it has vested.
In this case, the proximate cause of the loss of Tobias is the misappropriation of Robles,
but CSB is still liable under Art. 1911 of the NCC.
Art. 1911 Even when the agent has exceeded his authority, the principal is
solidarily liable with the agent if the former allowed the latter to act as though he had full
powers.
CSB is estopped in denying Robles’ authority, because, as the branch manager, he is
recognized within his field as to third persons as the general agent and is in general charge
of the corporation, with apparent authority commensurate with the ordinary business
entrusted him and the usual course and conduct thereof. Moreover, the bank admitted the
authority of its branch manager to transact outside of the bank premises. The act of
honoring the accounts of Tobias so opened is an acknowledgement by CSB of the
authority of Robles.