Facts:

In the case of Banco Filipino Savings and Mortgage Bank v. Court of Appeals, G.R. No. 132703, dated June 23, 2000, the petitioner Banco Filipino Savings and Mortgage Bank (Banco Filipino) engaged in a transaction with the respondent Tala Realty Services Corporation (Tala Realty). The transaction arose from Banco Filipino's need to unload some of its real estate holdings in order to comply with the General Banking Act, which limited banks from owning real property beyond fifty percent of their net worth. Banco Filipino sold certain branch sites to Tala Realty in 1981, intending to lease these properties back for its operations. Tala Realty was established to facilitate this transaction, acting as a corporate medium for Banco Filipino. However, in August 1992, Tala Realty demanded increased rent and other payments from Banco Filipino, threatening eviction if these terms were not met. Consequently, on April 20, 1994, stockholders of Banco Filipino filed a derivative suit agains

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Facts:

Background and Regulatory Framework

• The General Banking Act regulates the number of branch sites a bank may operate.
• Under this Act, a bank may own branch sites only up to 50% of its net worth.
• Banco Filipino had reached its allowable limit in branch site holdings and contemplated further expansion.

Transactions between Banco Filipino and Tala Realty

• Banco Filipino unloaded some of its branch site holdings by selling them to Tala Realty.
• Immediately thereafter, Banco Filipino leased the same branch sites from Tala Realty.
• Tala Realty was organized by the major stockholders of Banco Filipino and served as a transferee, allegedly holding the properties in trust for Banco Filipino.
• On March 26, 1979, Tala Realty obtained its registration from the Securities and Exchange Commission.

Specific Sale and Lease Arrangement

• On April 17, 1979, the board of directors of Banco Filipino authorized negotiations for selling its branch sites.
• On August 25, 1981, Banco Filipino executed separate deeds of sale transferring its branch sites to Tala Realty, and simultaneously entered into separate lease agreements for the same branch sites.
• A representative transaction involved the sale of four lots in Iloilo City (covered by TCT Nos. 62273 and 62274) for ₱2,110,000.00, which were leased back for a monthly rental of ₱21,000.00 over twenty years (renewable for another twenty years).
• The lease agreements for other branch sites contained substantially similar terms, differing primarily in the amount of rent due.

Dispute Arising from the Transactions

• Banco Filipino later contended that the series of sales and leasebacks had created an implied trust, whereby Tala Realty held the legal titles for Banco Filipino’s beneficial interest.
• Sometime in August 1992, Tala Realty demanded increased rentals, deposits, and goodwill, accompanied by threats of ejectment if the demands were not met.
• On April 20, 1994, some Banco Filipino stockholders initiated a derivative suit against Tala Realty before the SEC for the reconveyance of the properties, which was dismissed on the ground of lack of jurisdiction.
• Subsequent ejectment suits were filed by Tala Realty as Banco Filipino failed to comply with the revised terms.

Procedural History and Multiple Complaints

• Banco Filipino filed, on August 16, 1995, an action for recovery of real properties in the Regional Trial Court (RTC) of Iloilo City, Branch 28, on the basis of breach of trust.
• Between August and September 1995, Banco Filipino had filed sixteen additional complaints for recovery of various properties previously sold to Tala Realty, all with substantially similar pleadings.
• Tala Realty and several private respondents (including Pilar D. Ongking, Elizabeth H. Palma, Dolly W. Lim, Rubencito M. del Mundo, and Nancy L. Ty) filed separate motions to dismiss the complaint on grounds including forum-shopping, litis pendentia, lack of jurisdiction, failure to state a cause of action, and failure to implead indispensable parties.

Dismissal by the Lower Courts and Subsequent Petitions

• The RTC dismissed Banco Filipino’s complaint on April 22, 1996, after extensive pleadings and relying on various Supreme Court circulars, Rules of Court provisions, and case law.
• Banco Filipino’s motion for reconsideration was denied on June 27, 1996.
• Instead of pursuing a timely appeal by writ of error, Banco Filipino filed a petition for certiorari under Rule 65 before the Court of Appeals on July 24, 1996, alleging violations of due process and failure to allow it to prove the cause of action.
• The Court of Appeals dismissed the petition, holding that the petitioner’s recourse was patently inappropriate under Rule 65 when an ordinary appeal was available.
• After further delay and denied motions for reconsideration by the Court of Appeals in December 1997, Banco Filipino finally filed its subject petition for certiorari before the Supreme Court on March 9, 1998, advancing several arguments including alleged grave abuse of discretion and improper application of remedial law.

Issue:

Whether Banco Filipino’s petition for certiorari under Rule 65 is the proper remedy in light of its failure to file a timely appeal.

• Whether the special civil action for certiorari is available when there exists a plain, speedy, and adequate remedy by ordinary appeal.
• The proper delineation between the remedies of appeal and certiorari.

Whether the Court of Appeals committed grave abuse of discretion in dismissing Banco Filipino’s previous petition by determining that an appeal, rather than certiorari, was the appropriate remedial measure.

• Whether the alleged constitutional deficiencies concerning the form of decision affected the merits of the RTC’s ruling.
• Whether allegations about splitting causes of action were adequately considered in dismissing the complaint.

• Whether Banco Filipino’s delay and failure to timely exercise its right to appeal constitutes a jurisdictional lapse thereby barring its recourse to a petition for certiorari.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)