Case Digest (G.R. No. 107918)
Case Digest (G.R. No. 107918)
Facts:
Associated Bank, petitioner, filed a petition for review on certiorari (G.R. No. 107918, June 14, 1994, Supreme Court First Division, Kapunan, J., writing for the Court) challenging the Court of Appeals' November 18, 1992 decision affirming the Regional Trial Court (RTC), Quezon City, Branch 91's dismissal of its third‑party complaint for lack of jurisdiction.The underlying controversy began when private respondents Visitacion Serra Flores and Ma. Asuncion Flores sued Associated Bank in a complaint for violation of the Negotiable Instruments Law and damages, seeking recovery of P900,913.60 that Associated Bank had charged against their account after honoring sixteen checks that allegedly bore alterations to the payee name effected by their supervisor without their knowledge. Associated Bank answered and, with leave of court, filed a third‑party complaint for reimbursement, contribution and indemnity against the collecting/endorsing banks — Philippine Commercial International Bank (PCIB), Far East Bank & Trust Company (FEBTC), Security Bank & Trust Company (SBTC), and Citytrust Banking Corporation (CTBC) — on the theory that those banks, as collecting banks and Clearing House participants, bore responsibility under the Philippine Clearing House Corporation (PCHC) Clearing House Rules and Regulations.
The collecting banks raised jurisdictional objections and defenses: CTBC and PCIB contended the checks appeared regular on their face and invoked estoppel and PCHC clearing rules (including time limits and arbitration); SBTC moved to dismiss for failure to resort to arbitration under Section 36 of the PCHC Rules; FEBTC did not file a formal answer on record. Associated Bank maintained that the trial court had jurisdiction because the third‑party complaint was inextricably linked to the main action brought by the private plaintiffs.
The RTC, relying on PCHC Rules (notably Sections 3 and 36), dismissed Associated Bank's third‑party complaint for lack of jurisdiction, holding that disputes among clearing participants involving items cleared through the PCHC must first be submitted to the PCHC Arbitration Committee and that the plaintiffs in the main action, being non‑parties to the third‑party complaint, did not remove the arbitration obligation of the member banks. The RTC denied reconsideration. The Court of Appeals affirmed the RTC in toto on November 18, 1992. Associated Bank then filed the present Rule 45 petition for review on certiorari to the Supreme Court, expressly assailing the Court of Appeals' holding that the third‑party complaint fell within the PCHC's jurisdiction and not the regular court.
Issues:
- Did the Court of Appeals err in holding that Associated Bank's third‑party complaint against private respondent collecting banks falls within the jurisdiction of the Philippine Clearing House Corporation and not the regular courts?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)