The Supreme Court (SC) has ruled that probate courts, which settle a deceased person’s estate, may require banks to explain withdrawals from the deceased person’s accounts to determine whether the funds are part of the estate.
In a Decision penned by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division upheld the Regional Trial Court’s (RTC) order requiring Union Bank of the Philippines (UnionBank) to explain withdrawals from the accounts of the late Ignacio T. Arroyo (Arroyo) and submit related email exchanges.
During the settlement of Arroyo’s estate, the estate administrators, Bernardina Arroyo Tantoco and Alicia Rita Arroyo, discovered that money had been withdrawn from his UnionBank accounts after his death without the heirs’ knowledge.
They asked the RTC to require UnionBank to explain the withdrawals and submit additional records, including emails exchanged between bank officers and a certain Atty. Fe.
The RTC granted their request, and the Court of Appeals upheld the order.
UnionBank challenged the ruling before the SC, arguing that the RTC had exceeded its authority as a probate court. The bank claimed that the withdrawals were made under a survivorship agreement and were used, among others, to settle Arroyo’s existing obligations. It also argued that any attempt to recover the funds should be brought in a separate civil case.
The SC upheld the RTC.
The SC explained that while probate courts have limited powers, they may provisionally determine whether property belongs to a deceased person’s estate. Under Rule 87 of the Rules of Court, they may also require persons suspected of concealing or taking estate property to answer questions and account for it.
In this case, the bank accounts were admittedly in Arroyo’s name. The RTC merely sought to determine how much money was in the accounts when he died and whether the funds should be included in the estate.
The SC also rejected UnionBank’s argument that the administrators were improperly seeking to recover the money. It explained that estate administrators have a duty to identify, account for, and protect the deceased’s assets for the benefit of heirs and creditors.
The SC further stressed that it is the probate court, not the bank, that must determine whether funds covered by a survivorship agreement form part of the estate. UnionBank should not have applied Arroyo’s deposits to his alleged debts on its own, bypassing the estate settlement proceedings. The SC emphasized that creditors must file their claims before the probate court rather than independently taking estate assets to satisfy those claims. (Courtesy of the SC Office of the Spokesperson)
This press release is prepared for members of the media and the general public by the SC Office of the Spokesperson as a simplified summary of the SC’s Decision. For the SC’s complete discussion of the case, please read the full text of the Decision in G.R. No. E-02776 (Union Bank of the Philippines v. Bernardina Arroyo Tantoco and Alicia Rita M. Arroyo), July 7, 2026.
Originally published by the Supreme Court Public Information Office on 09 October 2026.
This post is a republication compliant with the Supreme Court Credit Attribution Policy.
Leave a Reply