Case Digest (G.R. No. L-15459) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Banco Filipino Savings and Mortgage Bank v. Bangko Sentral ng Pilipinas and the Monetary Board (G.R. No. 200678, June 4, 2018), petitioner Banco Filipino, a bank previously ordered closed and placed under receivership by the Monetary Board and the Philippine Deposit Insurance Corporation (PDIC), sought to compel BSP and its Monetary Board to approve and implement its revised business plan and to release financial assistance and regulatory reliefs. After this Court’s 1991 decision voiding Banco Filipino’s closure and directing its reorganization, Banco Filipino filed multiple suits for damages amounting to ₱18.8 billion and requested emergency loans from BSP under Republic Act No. 7653. Following protracted negotiations and seven business-plan revisions, the Monetary Board approved Resolution No. 1668 granting ₱25 billion in assistance, conditioned on Banco Filipino’s withdrawal of all its suits against BSP and MB. Petitioner resisted this condition and on October 20, 2010 fil Case Digest (G.R. No. L-15459) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Closure and Receivership of Banco Filipino
- In 1991, the Supreme Court declared void the Monetary Board’s 1985 closure and receivership order of Banco Filipino and directed its reorganization under Central Bank control.
- Republic Act No. 7653 (1993) created Bangko Sentral ng Pilipinas (BSP) as monetary authority and provided that closed banks be placed under the Philippine Deposit Insurance Corporation (PDIC) as receiver.
- Business Plan Negotiations and Regional Trial Court Petition
- Between 2003 and 2009, Banco Filipino submitted multiple revised business plans to BSP/Monetary Board seeking emergency loans and regulatory reliefs, subject to conditions including withdrawal of its P18.8 billion damage claims against BSP and Monetary Board.
- On July 8, 2004, Banco Filipino filed Civil Case No. 04-823 (Petition for Revival of Judgment) in RTC Makati to compel BSP to approve its business plan; the parties negotiated and proposed settlements through 2009.
- Civil Case No. 10-1042 and Court of Appeals Proceedings
- On October 20, 2010, Banco Filipino filed a Petition for Certiorari and Mandamus (Civil Case No. 10-1042) in RTC Makati, Branch 66, attacking BSP/Monetary Board’s imposition of the withdrawal condition. The RTC issued a temporary restraining order.
- BSP and Monetary Board moved to dismiss for lack of jurisdiction; after denial, they filed petitions for certiorari with the Court of Appeals (CA-G.R. SP Nos. 116627 & 116905). The CA issued a preliminary injunction (Feb. 14, 2011) and on July 28, 2011 dismissed Civil Case No. 10-1042 for lack of jurisdiction.
- Petition for Review on Certiorari to the Supreme Court
- On April 10, 2012, Banco Filipino filed this Petition for Review on Certiorari assailing the CA’s July 28, 2011 Decision and February 16, 2012 Resolution.
- BSP/Monetary Board moved to dismiss, arguing Banco Filipino lacked capacity to sue without PDIC’s joinder and that RTC had no jurisdiction over certiorari against a quasi-judicial agency.
Issues:
- Capacity and Authority to Sue
- Whether a closed bank under PDIC receivership may file a petition without joining PDIC as receiver.
- Jurisdiction over Certiorari Petitions
- Whether the Regional Trial Court has jurisdiction over a petition for certiorari against acts or omissions of BSP/Monetary Board.
- Whether BSP/Monetary Board was required to file a motion for reconsideration of the RTC’s interlocutory orders before seeking certiorari with the Court of Appeals.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)