Case Digest (G.R. No. 205966) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Bangko Sentral ng Pilipinas v. Feliciano P. Legaspi (G.R. No. 205966, March 2, 2016), petitioner Bangko Sentral ng Pilipinas (BSP) filed on April 10, 2008, before the Regional Trial Court (RTC), Branch 20, Malolos City, Bulacan, a complaint for annulment of title, revocation of certificate, and damages with an application for a temporary restraining order and writ of preliminary injunction. The complaint named as defendants Secretary Jose L. Atienza, Jr., Luningning G. De Leon, Engr. Ramon C. Angelo, Jr., former Norzagaray Mayor Matilde A. Legaspi, and incumbent Mayor Feliciano P. Legaspi (respondent). On May 13, 2008, the RTC granted the preliminary injunction, enjoining respondent and co-defendant Angelo from pursuing the construction and operation of a dumpsite on property covered by OCT No. P-858/Free Patent No. 257917, allegedly acquired by BSP. Respondent Legaspi moved to dismiss on August 15, 2008, arguing among others that the RTC lacked jurisdiction over BSP’s person Case Digest (G.R. No. 205966) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Complaint and Preliminary Injunction
- On April 10, 2008, Bangko Sentral ng Pilipinas (BSP) filed a Complaint for annulment of title, revocation of certificate, and damages, with application for TRO/preliminary injunction, against DENR Secretary Jose L. Atienza, Jr., Luningning G. De Leon, Engr. Ramon C. Angelo, Jr., ex-Mayor Matilde A. Legaspi, and Mayor Feliciano P. Legaspi before the RTC of Malolos City, Bulacan.
- The RTC issued a preliminary injunction on May 13, 2008 enjoining respondents from constructing or operating a dumpsite on the land covered by OCT No. P858/Free Patent No. 257917, subject of the complaint.
- Motion to Dismiss and RTC Orders
- On August 15, 2008, respondent Feliciano P. Legaspi moved to dismiss for lack of personal and subject matter jurisdiction, illegal representation (no Monetary Board authority; no OSG signature), and absence of assessed value allegations.
- BSP opposed, citing Monetary Board Resolutions No. 8865 (June 17, 2004), No. 805 (June 17, 2008), and No. 1005 (July 29, 2005), verification by Geraldine C. Alag (Director, Asset Management), and its right to private counsel. On January 20, 2009, the RTC denied the Motion to Dismiss, ruling it had acquired jurisdiction and that the Monetary Board validly delegated representation to BSP officers and private counsel. On April 3, 2009, it denied Legaspi’s motion for reconsideration, finding the attached tax declaration (assessed value P28,538,900; zonal value P145,162,080) sufficient.
- Court of Appeals and Supreme Court Proceedings
- Legaspi elevated the case to the CA via a Rule 65 petition. In its Decision dated August 15, 2012, the CA granted the petition, set aside the RTC’s January 20 and April 3, 2009 Orders, and dismissed BSP’s complaint. Its Resolution dated February 18, 2013 denied BSP’s motion for reconsideration.
- BSP filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court on March 13, 2013.
Issues:
- Did the RTC have exclusive original jurisdiction under BP 129 (as amended by RA 7691) over BSP’s real-property action?
- Was BSP’s engagement of private counsel lawful under RA 7653 and validly authorized by the Monetary Board?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)