If forgery was committed by an employee of the drawer whose signature was forged, does the relationship amount to estoppel such that the drawer is precluded in recovering from the drawee bank?

The bare fact that the forgery was committed by an employee of the party whose signature was forged can not necessarily imply that such party’s negligence was the cause of the forgery in the absence of some circumstances raising estoppel against the drawer. (Samsung Construction Co. v. Far East Bank and Trust Company, G.R. No. 129015, Aug. 13, 2004)