Case Digest (G.R. No. 200642)
Facts:
Banco Filipino Savings and Mortgage Bank v. Bangko Sentral ng Pilipinas and the Monetary Board arose from Banco Filipino’s long-running effort to enforce its business plan and claim P18.8 billion in damages against the Bangko Sentral ng Pilipinas (BSP) and the Monetary Board after those authorities conditioned the bank’s financial assistance on the withdrawal of its lawsuits. Banco Filipino was shut down in 1985, and in 1991 the Supreme Court declared the closure tainted by grave abuse of discretion and ordered its reorganization. In the 1990s and 2000s, under Republic Act No. 7653 (New Central Bank Act), Banco Filipino submitted and revised eight versions of a rehabilitation plan seeking loans and regulatory relief. BSP’s Monetary Board approved a P25 billion assistance package in December 2009 only on condition that the bank dismiss all pending cases and waive future claims. Banco Filipino refused to drop its suits and, on October 20, 2010, filed a petition for certiorari andCase Digest (G.R. No. 200642)
Facts:
- Parties and Historical Background
- Banco Filipino Savings and Mortgage Bank (Banco Filipino)
- A juridical entity authorized to operate as a banking institution.
- Ordered closed on January 25, 1985; closure declared void by the Supreme Court’s December 11, 1991 decision directing its reorganization.
- Respondents Bangko Sentral ng Pilipinas (BSP) and the Monetary Board
- BSP is the central monetary authority established under RA 7653 (New Central Bank Act).
- Exercises supervisory and regulatory powers over banks and quasi-banking institutions, including the power to place banks under receivership.
- Negotiations on Business Plan and Regulatory Relief
- From 2002 to 2009, Banco Filipino suffered heavy withdrawals and sought emergency loans and regulatory relief from BSP, submitting successive business plans.
- On December 4, 2009, the Monetary Board issued Resolution No. 1668 granting a ₱25 billion financial assistance and regulatory relief package, subject to conditions including the withdrawal with prejudice of all pending cases against BSP and the Monetary Board.
- Banco Filipino resisted the condition to dismiss its suits for ₱18.8 billion in damages, leading to continued negotiations, letters of dissent, and referral of the matter to private counsel (CVC Law).
- Proceedings in Civil Case No. 10-1042 and CA Appeals
- On October 20, 2010, Banco Filipino filed in RTC Makati Branch 66 a petition for certiorari and mandamus with prayer for TRO and WPI (Civil Case No. 10-1042) to declare the withdrawal-condition void and compel BSP to implement its business plan.
- The RTC granted a TRO on October 28, 2010, denied respondents’ motion to dismiss on November 17, 2010, and issued a WPI on November 18, 2010.
- Respondents sought certiorari relief in the Court of Appeals (CA-G.R. SP No. 116627 and supplemental petition), which on October 3, 2011 nullified the RTC’s TRO and WPI for lack of jurisdiction; denial of reconsideration followed on February 14, 2012.
- Meanwhile, on March 17, 2011, the Monetary Board issued Resolution No. 372.A placing Banco Filipino under PDIC receivership; related petitions (CA-G.R. SP No. 118599) remain pending before the CA.
- Banco Filipino elevated the CA’s October 3, 2011 decision and February 14, 2012 resolution to the Supreme Court in G.R. No. 200642.
Issues:
- Jurisdiction
- Whether the RTC had jurisdiction over the subject matter of Civil Case No. 10-1042.
- Whether the RTC had jurisdiction over BSP and the Monetary Board as respondents.
- Procedural and Standing Requirements
- Whether Banco Filipino needed PDIC’s authorization to file the petition while under receivership.
- Whether respondents were required to file a motion for reconsideration before elevating the case to the CA.
- Propriety of Ancillary Writs
- Whether the issuance of the TRO and WPI by the RTC was proper.
- Whether the parties committed forum shopping in pursuing parallel remedies.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)