Weck v. First Pennsylvania Banking & Trust Co.

31 Pa. D. & C.2d 557, 1963 Pa. Dist. & Cnty. Dec. LEXIS 384
CourtPhiladelphia County Court of Oyer and Terminer
DecidedAugust 28, 1963
Docketno. 8347-B
StatusPublished
Cited by1 cases

This text of 31 Pa. D. & C.2d 557 (Weck v. First Pennsylvania Banking & Trust Co.) is published on Counsel Stack Legal Research, covering Philadelphia County Court of Oyer and Terminer primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Weck v. First Pennsylvania Banking & Trust Co., 31 Pa. D. & C.2d 557, 1963 Pa. Dist. & Cnty. Dec. LEXIS 384 (Pa. Super. Ct. 1963).

Opinion

O’Donnell, J.,

This is a trespass action to recover the proceeds of a certified check. Plaintiff and her husband had a checking account (husband-wife account, either to draw thereon) in defendant bank. On December 18, 1959, plaintiff, then separated from her husband (divorced a year later,) ob[558]*558tained a certified check in the amount of $1,440 from defendant’s branch located in plaintiff’s apartment building. The $1,440 represented $1,000 drawn upon the checking account and $440 drawn upon a savings account also in the name of plaintiff and her husband.

Shortly after the certification of this check, defendant noted that it had overlooked a check drawn by plaintiff’s husband, which check was received and paid by defendant on the previous day. Consequently, there was not sufficient funds in the joint checking account to cover the check it had certified. Defendant’s teller promptly called on plaintiff, and informed her of this fact. The clerk requested the return of the certified check. Plaintiff complied, and on her return to the bank was given $440 in cash, which sum represented that portion of the check drawn upon the savings account. Plaintiff alleges that the $1,440 check was destroyed without her permission, in fact, against her will, hence she suffered damages of $1,000.

Subsequently several checks (some signed by plaintiff and her husband), were presented to defendant for payment and charged against the account. On August 17, 1960, defendant forwarded its treasurer’s check in the amount of $.14 payable to plaintiff and her husband with a letter stating that this was to close the checking account. Plaintiff and her husband endorsed and cashed this check. Each month between December 1959 and August 1960, when the account was closed by the $.14 treasurer’s check, plaintiff received bank statements showing the balances in the account, indicating the deposits, service charges, withdrawals by check and daily balances, and delivering the cancelled checks charged to the account.

The trial judge directed the jury to render a verdict in favor of defendant. Plaintiff filed motions for new trial and for judgment n.o.v., which motions were argued before the court en banc and denied.

[559]*559Plaintiff admits she surrendered the certified check to defendant’s teller after being informed of the bookkeeping error. Plaintiff’s contract with defendant permitted defendant to charge against the account checks made by her or her husband.1 She did not aver or offer any evidence that the checks charged against the account were improperly charged; in fact, she admitted all charges were proper.

Plaintiff testified she did not know how much was in the account at the time she accepted the certified check. She testified she left $268 in the checking account to cover anything that was outstanding. She also admitted she was told that the certified cheek wasn’t any good; that it should not have been issued because of insufficient funds in the account. She admitted receiving the bank statement on the account for December 1959 indicating the balance in the checking account on December 17, 1959 to be $458.02; and on December 18, 1959, $898.88; and the statement of July 27,1960 to August 17, 1960 showing the balance in the account as $.14; also endorsing jointly with her husband the check of $.14 forwarded to her on August 17,1960, representing the balance in the account when it was closed, which check was cashed by the bank on September 19, 1960.

Plaintiff did not object to the admission of the exhibits showing the status of the checking account (the three bank statements), except as to stating: “I have no objection to the figures showing the checks which were paid out of the account”; and later saying that she “objects to the date that may appear”.

Plaintiff did not object to the cancelled checks, also received in evidence, on this account (exhibits 7 to 11), except as to 11, the $810 check, to which she objected: “only the extent of showing the verity of date”. As to [560]*560this $810 check, it is noted it was drawn December 17, 1959, made by husband only, and paid by defendant on the same date, the day preceding the certification.

Nowhere did plaintiff assert or offer to prove that any of the checks charged against the account were not properly charged thereto, that the checks were not hers, her husband’s or their joint checks.

Further analyzing the bank account balances, it is to be noted that plaintiff, jointly with her husband, after the certification involved herein, executed checks total-ling $312.58 (exhibit D-l, 7, 8 and 9); also bank service fees of $5.50 were charged, about which she made no protest.

Considering these facts, also her testimony that when she applied for the certified check, she left a fund “$268 in the checking account to cover anything that was outstanding”, and the contract between plaintiff, the bank and her husband, and the notice on each bank statement, viz:

“Please Examine at Once. If No Error Is Reported in Ten Days the Account Will Be Considered Correct”

It would be most unrealistic and most unjust for plaintiff to argue to a jury that she lost $1,000.

When defendant learned of the marital problems of plaintiff, it notified the parties both signatures were required for future withdrawals.

There was a check to the Internal Revenue drawn by plaintiff’s husband only in the amount of $80.80, dated December 15,1959, charged January 11,1960. A question was raised as to this because it was charged to the account after defendant required the joint signatures. The bank honored it, not wishing to jeopardize its depositor’s status with the government. In all fairness, such examination as to this item was unnecessary and improper unless its authenticity was questioned. Plaintiff, however, after notice of its charge against the ac[561]*561count never complained about it except at trial. Note, however, she left a sufficient fund to cover such a contingency.

Plaintiff testified as to various protests to defendant. All her protests, however, concerned the nonreturn or destruction of the certified check. She never protested as to any item charged against the account, as to the amount, date, or authority to charge the various items. She admits defendant accounted, by proper disbursement, for all the funds ever deposited in the checking account.

Plaintiff did not aver or offer any evidence to show she changed her position because of the certification and no third party rights were involved herein. Plaintiff has not presented any evidence that she gave value for the certified check.

Defendant unequivocally by oral and documentary evidence established that the certified check was mistakenly issued to plaintiff, which fact plaintiff did not rebut. In fact, by her testimony — also, by her conduct, she confirmed the accuracy of the accounting of defendant for every cent deposited in the account. It was therefor the opinion of the trial judge that she failed to prove damages or injury.

The delivery by a bank to a depositor of his cancelled checks, and a statement of his account, constitutes the rendition of an account. The depositor is bound to examine the account with due diligence, and is bound by an account stated if he fails to advise the bank of any error without unreasonable delay.2

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Related

Weck v. First Pennsylvania Banking & Trust Co.
195 A.2d 111 (Superior Court of Pennsylvania, 1963)

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Bluebook (online)
31 Pa. D. & C.2d 557, 1963 Pa. Dist. & Cnty. Dec. LEXIS 384, Counsel Stack Legal Research, https://law.counselstack.com/opinion/weck-v-first-pennsylvania-banking-trust-co-paoytermctphila-1963.