Facts:

The case at hand involves two consolidated petitions for review on certiorari: G.R. No. 178696, filed by the Bangko Sentral ng Pilipinas (BSP) and its Monetary Board (MB), and G.R. No. 192607, filed by Banco Filipino Savings and Mortgage Bank (BFSMB). Both cases arose from decisions and resolutions of the Court of Appeals with respect to lower court rulings regarding BFSMB's operations after its closure. The petitioner in G.R. No. 178696 seeks to annul the appellate court's decision that the BSP is liable for the obligations of the former Central Bank (CB), while the respondent seeks to reverse the dismissal of its petition for the revival of a prior Supreme Court judgment concerning its reorganization and financial assistance.

BFSMB commenced operations as a savings and mortgage bank on July 9, 1964, after being authorized by the Central Bank under Resolution No. 223 dated February 14, 1963. However, it was placed under conservatorship on July 27, 1984, leading to furth

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Facts:

Commencement, Conservatorship, and Closure of BFSMB

• BFSMB commenced operations on July 9, 1964, pursuant to Monetary Board (MB) Resolution No. 223 dated February 14, 1963.
• In MB Resolution No. 955 dated July 27, 1984, BFSMB was placed under the conservatorship of Basilio Estanislao.
• MB Resolution No. 75 dated January 25, 1985 ordered BFSMB’s closure on the grounds of insolvency and the likelihood that continuation in business would cause probable loss to depositors and creditors.

Petition for Certiorari and Mandamus in G.R. No. 70054

• On February 28, 1985, BFSMB filed a petition for certiorari and mandamus to annul MB Resolution No. 75, alleging it was enacted without or in excess of jurisdiction and with grave abuse of discretion.
• The petition was consolidated with eight other cases, and in a consolidated decision dated December 11, 1991, the Court annulled the closure order and directed that BFSMB be reorganized and allowed to resume business under the comptrollership of the Central Bank and its Monetary Board.

Reorganization and Reopening under a New Legal Framework

• Republic Act No. 7653 (The New Central Bank Act of 1993) took effect on July 6, 1993, abolishing the old Central Bank and establishing the Bangko Sentral ng Pilipinas (BSP).
• Under the same law, the Central Bank continued to exist as the Central Bank-Board of Liquidators (CB-BOL) for the purpose of liquidating assets and liabilities not transferred to the BSP.
• During a meeting on November 6, 1993, the BSP Monetary Board (BSP-MB) resolved to allow BFSMB to reopen, subject to conditions including submission of a proposed organization and collateralization of its advances from the BSP.
• BFSMB eventually reopened on July 1, 1994, operating under the comptrollership of the BSP.

Financial Rearrangements and Business Plan Submission

• A Memorandum of Agreement was entered into on December 20, 1999, wherein BFSMB agreed to repay a substantial amount (P3.67 billion) by dacion en pago of some real properties, which were advances originally extended by the defunct Central Bank.
• In December 2002, BFSMB experienced massive withdrawals, prompting it to request emergency financial assistance and additional support from the BSP in October 2003.
• On April 14, 2004, BFSMB submitted a long-term business plan seeking reorganization and financial support, asserting that the BSP—having “stepped into the shoes of the old Central Bank”—should reorganize the bank by restoring its 89-branch network and ensuring operational stability.

Filing of the Petition for Revival of Judgment

• On July 14, 2004, BFSMB filed its Petition for Revival of Judgment to enforce the 1991 Supreme Court decision in G.R. No. 70054.
• The petition sought:
• Revival of the judgment directing the reorganization of BFSMB.
• Enforcement of reliefs including the restoration of the nationwide branch network and assurance of safe operations for depositors, creditors, and the public.
• Approval of BFSMB’s business plan and financial arrangements similar to those granted to other banks.

Respondents’ Motions to Dismiss and Subsequent Trial Court Orders

• BSP-MB and CB-BOL moved to dismiss the petition on multiple grounds including:
• Non-payment of requisite docket fees, given the projected release of a large sum (P9 billion).
• Prescription, as the petition was filed more than 12 years after the 1991 judgment became final.
• Lack of cause of action against BSP-MB (not being parties or successors-in-interest of the defunct CB-MB).
• Allegations that the petition was essentially one for mandamus and that its reliefs extended beyond the original judgment.
• Claims of forum shopping and improper authorization of the petition’s signatories.
• The Regional Trial Court (RTC), in its Order dated July 22, 2005, denied the separate motions to dismiss, ruling that the petition stated a cause of action and that the docket fee issue was immaterial since the amount was merely projected.
• On August 25, 2006, the RTC reaffirmed its decision, denying the motions for reconsideration and granting an additional period for CB-BOL to file its pleadings.

Court of Appeals and Consolidated Proceedings

• Parallel petitions were filed in the Court of Appeals:
• CA-G.R. SP No. 96831 by BSP-MB, challenging the RTC ruling on dismissal.
• CA-G.R. SP No. 96280 by CB-BOL concerning BFSMB’s Petition for Revival of Judgment.
• In CA-G.R. SP No. 96831 (Decision dated April 12, 2007), the Court of Appeals dismissed BSP-MB’s petition for certiorari, holding that no grave abuse of discretion was committed by the RTC.
• In CA-G.R. SP No. 96280 (Decision dated September 3, 2008), the Court of Appeals annulled the RTC orders and dismissed BFSMB’s Petition for Revival of Judgment on the ground that it was filed beyond the reglementary period, i.e. prescription had already set in.

Supreme Court Resolution and Final Determinations

• The Supreme Court consolidated the two petitions (G.R. Nos. 178696 and 192607) on the same factual background and subject matter.
• It found merit in BSP-MB’s petition while holding that BFSMB’s petition for revival was untimely and lacked merit, noting that:
• The petition for revival was filed more than 12 years after the final judgment, thereby being barred by prescription.
• Even aside from prescription, the judgment obligation had been extinguished through partial performance and the bank’s reopening under BSP’s comptrollership.
• The Court underscored that the reliefs sought by BFSMB extended beyond the scope of the original 1991 decision and could not be imposed through mere revival of judgment.

Issue:

Issues Raised in G.R. No. 178696 (BSP-MB’s Petition)

• Whether the Court of Appeals erred in holding that the Bangko Sentral ng Pilipinas (BSP) succeeded in the liabilities of the defunct Central Bank, as opposed to the Central Bank-Board of Liquidators (CB-BOL), pursuant to Section 132(e) of R.A. 7653.
• Whether it was erroneous to include a cause of action against BSP-MB in BFSMB’s Petition for Revival of Judgment, given that the BSP-MB was neither a party to the original judgment (G.R. No. 70054) nor a transferee pendente lite.
• Whether the Court of Appeals mistakenly ruled that BFSMB’s Petition for Revival was not barred by prescription, despite the apparent lapse beyond the ten-year period.
• Whether the reliefs sought by BFSMB extended beyond the ambit of the original judgment and were thus inappropriate for judicial compulsion.
• Whether issues pertaining to the exercise of discretionary powers (e.g., conditions for the bank’s reorganization and approval of its business plan) could be compelled through revival of judgment.

Issues Raised in G.R. No. 192607 (BFSMB’s Petition)

• Whether the Court of Appeals departed from established judicial procedure by granting the petition for certiorari and prohibition without a finding of grave abuse of discretion on the part of the RTC.
• Whether the Court of Appeals erred in addressing substantive matters – such as the capacity of BFSMB to initiate the petition, the tolling of prescription, and the doctrine of stare decisis – without properly considering the record and the earlier decision in G.R. No. 70054.
• Whether BFSMB’s subsequent abandonment of its position after submitting a revised business plan rendered its original petition moot and without merit.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Timeliness and Prescription in Revival of Judgment

• The Supreme Court reiterated that the execution of a final and executory judgment must occur either by motion within five years or, if no motion is filed, by reviving the judgment through an action within ten years from its finality.

• The judgment in G.R. No. 70054 being final on February 4, 1992, meant that BFSMB had only ten years to file its petition for revival; filing in 2004 exceeded this period.

Limitations of the Revival Remedy

• The remedy of revival of judgment is confined strictly to enforcing the existing judgment and cannot be used to modify or add reliefs beyond what was originally decreed.
• Any expansion of the judgment’s mandates through revival is not permissible, especially when the obligation has been partially performed (e.g., the reopening and reorganization of BFSMB unde

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