Case Digest (G.R. No. 200678)
Facts:
Banco Filipino Savings and Mortgage Bank v. Bangko Sentral ng Pilipinas and The Monetary Board, G.R. No. 200678, June 04, 2018, Supreme Court Third Division, Leonen, J., writing for the Court.The dispute arises from the long-running post-closure dealings between Banco Filipino Savings and Mortgage Bank (petitioner) and the central monetary authorities. After this Court’s 1991 decision in Banco Filipino Savings & Mortgage Bank v. Monetary Board and Central Bank of the Philippines ordering the bank’s reorganization and resumption of business, Banco Filipino pursued various claims (including a damages claim of P18.8 billion) and thereafter sought Bangko Sentral’s assistance as it experienced liquidity pressures in 2002–2004. Bangko Sentral (created by Republic Act No. 7653) conditioned any financial assistance on compliance with statutory requirements and an approved rehabilitation plan; negotiations produced multiple revised business plans and, in December 2009, Monetary Board Resolution No. 1668 approving financial assistance subject to terms, including withdrawal of pending suits against Bangko Sentral and related quitclaims by key actors.
When Banco Filipino contested certain settlement conditions, it brought a Petition for Revival of Judgment (Civil Case No. 04‑823) in the Regional Trial Court (RTC), Makati (Branch 62), and later filed a Petition for Certiorari and Mandamus (Civil Case No. 10‑1042) in Branch 66, Makati, on October 20, 2010, seeking to compel Bangko Sentral and the Monetary Board to approve and implement its business plan and to enjoin coercive acts. The RTC (Branch 66) granted a temporary restraining order on October 28, 2010, and later issued a writ of preliminary injunction. Bangko Sentral and the Monetary Board moved to dismiss and then filed petitions for certiorari with the Court of Appeals (CA) challenging the RTC’s orders (docketed in CA as CA‑G.R. SP Nos. 116627 and 116905).
The CA initially enjoined the RTC from further proceedings (February 14, 2011 resolution) and, after briefing and oral argument, issued a Decision on July 28, 2011 in CA‑G.R. SP No. 116905 annulling the RTC’s November 17, 2010 order and dismissing Civil Case No. 10‑1042 for lack of jurisdiction, holding that special civil actions against quasi‑judicial agencies belong exclusively to the Court of Appeals. The CA denied Banco Filipino’s motion for reconsideration in a February 16, 2012 resolution. Banco Filipino then filed a petition with the Supreme Court—styled in the record as a Petition for Revi...(Subscriber-Only)
Issues:
- Did petitioner Banco Filipino have the legal capacity to file this Petition for Review without joining its statutory receiver, the Philippine Deposit Insurance Corporation (PDIC)?
- Do trial courts have jurisdiction to take cognizance of petitions for certiorari challenging acts or omissions of the Monetary Board of the Bangko Sentral ng Pilipinas?
- Were respondents required to file a motion for reconsideration of the RTC’s denial of their motion to dismiss before petitioning the Court of Appeals?
- Did the RTC validly acquire jurisdiction over respondents Bang...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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