Facts:

The case involves Banco Filipino Savings and Mortgage Bank (Banco Filipino), which filed a Petition for Review on Certiorari in the Supreme Court against the Bangko Sentral ng Pilipinas (Bangko Sentral) and the Monetary Board. The inquiries stem from a Court of Appeals decision issued on October 3, 2011, which overturned a temporary restraining order (TRO) and a writ of preliminary injunction (WPI) granted by the Regional Trial Court (RTC) of Makati City concerning Civil Case No. 10-1042. Banco Filipino is a banking entity that has experienced tumultuous circumstances, including being ordered closed on January 25, 1985, with the closure later deemed as having been executed with grave abuse of discretion by the Supreme Court in a decision dated December 11, 1991.

Following the Supreme Court's directive for its reorganization, Banco Filipino submitted several complaints, including a claim worth P18.8 billion. Moreover, the shift to Bangko Sentral as the Philippines' moneta

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Facts:

Background and Institutional Context

• Banco Filipino Savings and Mortgage Bank (Banco Filipino) is a banking institution that was originally ordered closed on January 25, 1985.
• The closure was later declared tainted with grave abuse of discretion by the Supreme Court on December 11, 1991, which also directed the reorganization of Banco Filipino under the comptrollership of both the Central Bank and the Monetary Board.
• Banco Filipino had initiated several legal actions including filing a claim for damages amounting to P18,800,000,000.00.
• Bangko Sentral ng Pilipinas (Bangko Sentral) is the central monetary authority, established under Republic Act No. 7653, and exercises regulatory functions over banking institutions and non-bank financial institutions with quasi-banking functions.
• The Monetary Board, acting through Bangko Sentral, is empowered to place banks under receivership and impose administrative sanctions based on violations of banking laws and regulations.

Factual Antecedents and Negotiations

• The case shares a common factual background with G.R. No. 200678, which involved a Rule 45 petition concerning the denial of a motion to dismiss in Civil Case No. 10-1042.
• On December 11, 1991, the Supreme Court’s decision in Banco Filipino Savings & Mortgage Bank v. Monetary Board and Central Bank of the Philippines voided the Monetary Board’s earlier closure and receivership order and allowed Banco Filipino to resume business under supervision.
• Various communications between Banco Filipino and Bangko Sentral occurred from 2003 to 2010.
• In 2003, Banco Filipino sought financial assistance exceeding P3,000,000,000.00, accompanied by a detailed business plan submission and negotiations over the terms for such aid.
• Multiple letters and proposals from both parties led to several revisions of Banco Filipino’s business plan.
• A key component emerging from this negotiation was Bangko Sentral’s requirement that Banco Filipino withdraw its pending legal cases, including its P18,800,000,000.00 damage claim, as a condition for financial assistance and regulatory relief.

Filing and Issuance of Writs

• On October 20, 2010, amid the negotiations, Banco Filipino filed a Petition for Certiorari and Mandamus in the Regional Trial Court (RTC) of Makati City (Civil Case No. 10-1042).
• The petition requested the issuance of a Temporary Restraining Order (TRO) and a Writ of Preliminary Injunction (WPI) against Bangko Sentral and the Monetary Board.
• Banco Filipino alleged that the respondents committed grave abuse of discretion by mandating the withdrawal of its suits and future claims as a condition to its business plan approval.
• The RTC later granted a TRO (October 28, 2010 Order) and a WPI (November 18, 2010 Order) directing the respondents to implement the approved business plan and refrain from coercive measures.
• Respondents filed motions to dismiss the RTC’s orders, arguing lack of jurisdiction. They eventually elevated the dispute to the Court of Appeals (CA) via separate petitions, including a Petition for Certiorari (docketed as CA-G.R. SP No. 116627).

Banco Filipino’s Receivership

• On March 17, 2011, the Monetary Board issued Resolution No. 372.A, placing Banco Filipino under receivership due to its inability to operate safely for depositors and creditors.
• The Philippine Deposit Insurance Corporation (PDIC) was designated as the receiver, thereby assuming control over the bank’s assets, liabilities, and legal actions.
• Subsequent proceedings involved petitions challenging the receivership, but the relevant issues were compounded by the fact that Banco Filipino’s representation was being conducted by its executive officers rather than through PDIC.

Jurisdictional and Procedural Issues

• The trial court’s issuance of the TRO and WPI raised questions regarding its jurisdiction over both the subject matter (an ancillary writ tied to a main action) and the persons of the respondents.
• It was noted that under Rule 65, Section 4 of the Rules of Court, petitions involving acts or omissions of a quasi-judicial agency (such as the Monetary Board) should be filed in the CA.
• The fact that Banco Filipino was under receivership required that any legal action be undertaken by or with the authorization of its statutory receiver, PDIC.
• The CA ultimately reversed and annulled the RTC’s grant of the TRO and WPI, stressing the trial court’s lack of jurisdiction and the impropriety of issuing ancillary writs without a valid, pending main action.

Issue:

Jurisdictional Authority

• Whether the trial court had jurisdiction over the subject matter of the petition, including the ancillary TRO and WPI, and over the persons of the respondents.
• Whether the proper forum was observed given that actions involving acts or omissions of a quasi-judicial agency should have been filed with the CA.

Propriety of Issuance of the TRO and WPI

• Whether the issuance of temporary restraining orders and preliminary injunctions, as mere ancillary remedies, was warranted in a case devoid of an ongoing main action or pending controversy.
• Whether retaining such provisional remedies following the final disposition of the main case renders them moot and academic.

Forum Shopping

• Whether both parties engaged in forum shopping by initiating parallel or subsequent proceedings in different courts regarding overlapping issues.

Authorization to Litigate under Receivership

• Whether Banco Filipino was validly entitled to file the petition without proper authorization from the PDIC, its statutory receiver, especially given that its powers had been suspended.

Impact of the Prior Final and Executory Decision

• Whether the finality of the decision in G.R. No. 200678, which disposed of the main action, precludes any relief through ancillary writs in the instant petition.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)