GONZALES, Jerome DP.

BSLM 3C

CA Agro-industrial vs. Court of Appeals, 3 March 1993

G.R No. 90027

DOCTRINE:
The rule is that access to a rented safety deposit box can only be granted when both the owner
and the person who rented it are present simultaneously.

FACTS:
CA Agro-industrial and Pugao entered into a contract where Pugao bought two parcels of land
for PHP 350,525, the title of which would be transferred to Pugao after settling the full payment,
which included an initial down payment of P75,725. Pugao and a representative from CA Agro-
industrial went to the Sea Trust Banking Company to rent a safety deposit box where the land
title was kept. Meanwhile, Mrs. Ramos expressed interest in buying two sqm of the land, but
when Aguirre, Pugao, and the representative from the bank opened the safety deposit box, the
title of the land could not be found. As a result, Mrs. Ramos withdrew her interest in buying the
land, and the petitioner filed a complaint for damages against the bank. The Regional Trial Court
dismissed the petitioner's claim, which led the petitioner to appeal the decision.

ISSUE:
Whether or not the relationship between the commercial bank and another party is similar to that
of a bailor and bailee.

RULING:
The rules surrounding safety deposit boxes can be found in General Banking Act Section 72 (a),
which states that the bank's rented safety deposit boxes fall under the category of receiving
documents, titles, and funds, among others. The safety deposit box can be opened by either the
petitioner Aguirre or Pugao using the guard key that the bank owns. Therefore, the Court ruled
that as per Title 1, Book IV of the Civil Code, the SBTC would be held responsible if found
guilty of fraud, negligence, delay, or violation of the terms of the agreement while fulfilling their
obligation.