Case Digest (G.R. No. 200678)
Facts:
The case involves Banco Filipino Savings and Mortgage Bank (Banco Filipino) as the petitioner and Bangko Sentral ng Pilipinas (Bangko Sentral) along with the Monetary Board as respondents. The events leading to this case began with the closure of Banco Filipino, which was ordered by the Monetary Board. Following this closure, the Philippine Deposit Insurance Corporation (PDIC) was designated as the receiver of the bank. This meant that Banco Filipino could only engage in legal actions through the PDIC. On December 11, 1991, the Supreme Court ruled in a previous case that the closure and receivership of Banco Filipino were void, directing the Monetary Board to allow the bank to resume operations. Subsequently, Banco Filipino filed multiple complaints, including a claim for damages amounting to P18,800,000,000.00.
In 2002, Banco Filipino faced significant financial difficulties, prompting it to seek assistance from Bangko Sentral. The bank requested over P3 billion in financi...
Case Digest (G.R. No. 200678)
Facts:
Background of the Case
Banco Filipino Savings and Mortgage Bank (Banco Filipino) was ordered closed by the Bangko Sentral ng Pilipinas (BSP) and placed under receivership of the Philippine Deposit Insurance Corporation (PDIC). Banco Filipino filed several complaints, including a claim for damages amounting to P18.8 billion. The bank was later allowed to resume business after a Supreme Court decision in 1991 declared the closure void.
Financial Crisis and Negotiations
In 2002, Banco Filipino faced heavy withdrawals and sought financial assistance from BSP. After multiple negotiations and revisions of its business plan, BSP approved a P25 billion financial assistance package in 2009, subject to conditions, including the withdrawal of all pending cases against BSP and the Monetary Board.
Legal Proceedings
Banco Filipino rejected the condition to withdraw its cases, leading to a legal dispute. It filed a Petition for Certiorari and Mandamus in the Regional Trial Court (RTC) of Makati, alleging BSP and the Monetary Board acted arbitrarily. The RTC issued a temporary restraining order, but BSP and the Monetary Board challenged the RTC's jurisdiction, filing a Petition for Certiorari with the Court of Appeals (CA). The CA dismissed the case, ruling the RTC lacked jurisdiction over the matter.
Issue:
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Ruling:
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Ratio:
- Capacity to Sue: Under Republic Act No. 7653, a bank under receivership loses its capacity to sue or be sued except through its receiver. PDIC, as the statutory receiver, has the exclusive authority to represent Banco Filipino in legal actions.
- Jurisdiction: Special civil actions, such as petitions for certiorari against quasi-judicial agencies, must be filed with the CA, not the RTC. The RTC’s assumption of jurisdiction was erroneous.
- Procedural Requirements: BSP and the Monetary Board were excused from filing a motion for reconsideration before seeking certiorari in the CA because the RTC’s lack of jurisdiction was a fundamental issue that could be raised directly.