1. Court and Parties

Court: Central Jakarta District Court (Pengadilan Negeri Jakarta Pusat) First instance civil judgment.

Plaintiff: Stefi Grace (Indonesian citizen), acting for herself and as wife and heir of the late Kent Lisandi (deceased 10 March 2025).

Defendants:

1. Rohmat Setiawan – Defendant I
2. Sumarningsih (wife of Defendant I) – Defendant II
3. Aris Setyawan – Defendant III (Branch Manager of Maybank KC Cilegon)
4. PT Bank Maybank Indonesia Tbk – Defendant IV

The lawsuit is based on Unlawful Act (Perbuatan Melawan Hukum) under Articles 1365 and 1367 of the Indonesian Civil Code (KUHPerdata).

2. Background of the Case

A. Initial Loan Arrangement (July–November 2024)

• In July 2024, Defendant I asked Plaintiff to help provide funds for a project called “Business Mobile Bundling Devices Service Provision.”
• Defendant I claimed he needed to show financial capability to obtain credit facilities from Maybank.
• Plaintiff agreed to assist by placing funds into Defendant I’s Maybank giro account.

B. Gradual Transfers by Plaintiff

Between July and November 2024, Plaintiff transferred funds in stages to Defendant I’s Maybank account as cash collateral.

The total amount placed by Plaintiff:

Rp 30,000,000,000 (thirty billion rupiah)

The funds were allegedly only meant to be displayed as proof of financial capacity and later withdrawn by Plaintiff.

3. Legal Instruments Created (11 November 2024)

On 11 November 2024, the following were executed:

1. Deed of Acknowledgment of Debt (No. 57)

   • Defendant I acknowledged debt to Plaintiff of Rp 36,685,000,000
   • Due date: 25 November 2024
   • Defendant II (wife) approved.

2. Special Power of Attorney (No. 58)

   • Authorized Plaintiff to withdraw Rp 30 billion without further confirmation.

3. Cheque No. CU220276

   • Given to Plaintiff for withdrawal on 25 November 2024.

4. Bank Statement issued by Maybank (through Defendant III)

   • Confirmed Plaintiff’s authority to withdraw the funds.

4. The Alleged Fraud

A. False Police Report

On 20 November 2024 (5 days before withdrawal date):

• Defendant I filed a police report claiming the cheque series, including CU220276, was lost.
• This blocked Plaintiff from cashing the cheque.

B. Criminal Development

Plaintiff filed a police complaint for false reporting.

On 19 December 2024:

• Defendant I was officially named a suspect for filing a false report.

5. Discovery of Collateralization

Plaintiff later discovered:

• On 13 November 2024, the Rp 30 billion had already been pledged as cash collateral for a financing facility granted to Defendant II.

• This was done through:

  • Mudharabah Financing Facility Amendment Agreement
  • Deposit/Giro Pledge Agreement

These agreements were signed between:

• Defendant I
• Defendant II
• Defendant IV (Maybank)
• Facilitated by Defendant III (Branch Manager)

Plaintiff alleges:

• This was done without her knowledge or consent.
• Defendants knew the funds belonged to Plaintiff.
• The bank violated the prudential banking principle.

6. Plaintiff’s Legal Arguments

Plaintiff bases her claim on:

Article 1365 Civil Code

(Unlawful act causing loss)

Elements:

1. Unlawful act
2. Fault
3. Damage
4. Causal relationship

Plaintiff argues all elements are fulfilled.

Article 1367 Civil Code

(Employer liability)

Plaintiff argues:

• Maybank is strictly liable for actions of its employee (Defendant III).
• Defendant III acted within employment capacity.
• Therefore Maybank bears responsibility.

Article 1320 & 1340 Civil Code

• Agreements must not harm third parties.
• The financing agreement harmed Plaintiff.
• Therefore it should be declared null and void (batal demi hukum).

7. Allegations Against Each Defendant

Defendant I

• Filed false loss report.
• Intentionally blocked withdrawal.
• Used Plaintiff’s funds as collateral.
• Caused Rp 30 billion to be frozen.

Defendant II

• Approved debt acknowledgment.
• Used and benefited from financing secured by Plaintiff’s money.

Defendant III (Branch Manager)

• Knew origin of funds.
• Issued guarantee letter on 11 November 2024.
• Facilitated collateralization.
• Failed prudential banking duties.

Defendant IV (Maybank)

• Authorized financing.
• Ignored Plaintiff’s rights.
• Allowed use of third-party funds as collateral.
• Violated banking prudence.
• Responsible under employer liability (Art. 1367).

8. Plaintiff’s Claimed Losses

Material Loss:

• Rp 30,000,000,000 (principal funds)

Immaterial Loss:

• Stress, uncertainty, reputational harm (The file is truncated before the final quantification, but immaterial damages are claimed.)

9. Legal Relief Requested by Plaintiff

Plaintiff requests the Court to:

1. Declare Defendants committed an unlawful act.
2. Declare the financing agreements dated 13 November 2024 null and void.
3. Order return of Rp 30 billion.
4. Hold Defendants jointly liable.
5. Possibly award immaterial damages.

(The document provided is primarily the statement of claim; the final operative ruling is not shown in the provided text.)

10. Core Legal Issue

At its heart, the case concerns:

Whether a bank and its branch manager may lawfully accept and pledge funds that they allegedly knew belonged to a third party, without that third party’s consent, and whether such conduct constitutes an unlawful act under Indonesian civil law.

11. Overall Structure of the Dispute

1. Plaintiff places Rp 30B to help Defendant I obtain project credibility.
2. Debt acknowledgment + withdrawal authority granted.
3. Defendant I files false lost-cheque report.
4. Funds secretly pledged as collateral for Defendant II’s financing.
5. Plaintiff cannot withdraw.
6. Criminal investigation confirms false reporting.
7. Civil lawsuit filed for unlawful act.