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POLO S. PANTALEON v. AMERICAN EXPRESS INTERNATIONAL, INC.

G.R. No. 174269, May 8, 2009, Tinga, J.

Generally, the relationship between a credit card provider and its card holders is that of creditor-debtor, with
the card company as the creditor extending loans and credit to the card holder, who as debtor is obliged to
repay the creditor. This relationship already takes exception to the general rule that as between a bank and its
depositors, the bank is deemed as the debtor while the depositor is considered as the creditor.

Facts:
An incident in Amsterdam happened which involved the delay of American Express Card to approve
Pantaleon’s credit card purchases worth US$13,826.00 at the Coster store.
Because of his plight, Pantaleon filed a complaint for moral and exemplary damages before the RTC
against American Express. He said that he and his family experienced inconvenience and humiliation due to the
delays in credit authorization. The RTC rendered a decision in favor of Pantaleon. The CA, however, reversed
the award of damages in favor of Pantaleon, holding that AmEx had not breached its obligations to Pantaleon,
as the purchase at Coster deviated from Pantaleon's established charge purchase pattern.

Issue: Whether American Express breached its obligation to Pantaleon.

Ruling:
YES. American Express breached its obligation to Pantaleon. Notwithstanding the popular notion that
credit card purchases are approved "within seconds," there really is no strict, legally determinative point of
demarcation on how long must it take for a credit card company to approve or disapprove a customer’s
purchase, much less one specifically contracted upon by the parties. Yet this is one of those instances when
"you’d know it when you’d see it," and one hour appears to be an awfully long, patently unreasonable length of
time to approve or disapprove a credit card purchase. It is long enough time for the customer to walk to a bank a
kilometer away, withdraw money over the counter, and return to the store.
Generally, the relationship between a credit card provider and its card holders is that of creditor debtor,
with the card company as the creditor extending loans and credit to the card holder, who as debtor is obliged to
repay the creditor. This relationship already takes exception to the general rule that as between a bank and its
depositors, the bank is deemed as the debtor while the depositor is considered as the creditor.