Facts:

The case involves a petition for review on certiorari filed by the Bangko Sentral ng Pilipinas (BSP) and the members of its Monetary Board against the Rural Bank of San Miguel (Bulacan), Inc. (RBSM), represented by its president and principal stockholder, Hilario P. Soriano. The events leading to this case began with a letter-complaint dated May 19, 1999, filed by Soriano, accusing BSP officials—Deputy Governor Alberto V. Reyes, Director Wilfredo B. Domo-Ong, and bank examiner Herminio C. Principio—of unprofessional conduct, which allegedly violated the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019) and the Code of Conduct and Ethical Standards for Public Officials and Employees (Republic Act No. 6713). In response, the Monetary Board established an Ad-Hoc Committee on May 26, 1999, to investigate the complaint. After conducting hearings, the Committee issued a resolution on February 16, 2000, recommending the dismissal of the complaint due to lack of merit. The...

Facts:

1. Origins of the Case:

   • The case originated from a letter-complaint dated May 19, 1999, filed by Hilario P. Soriano, the president and principal stockholder of Rural Bank of San Miguel (Bulacan), Inc. (RBSM). The complaint charged Bangko Sentral ng Pilipinas (BSP) officials—Deputy Governor Alberto V. Reyes, Director Wilfredo B. Domo-Ong, and bank examiner Herminio C. Principio—with unprofessionalism in violation of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) and Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees).

2. Investigation and Initial Resolution:

   • An Ad-Hoc Committee was created by the Monetary Board of the BSP on May 26, 1999, to investigate the complaint. After due proceedings, the Committee issued a resolution dated February 16, 2000, recommending the dismissal of the complaint for lack of merit. The Monetary Board adopted this recommendation in its Resolution No. 257 dated February 18, 2000, absolving the BSP officials from any administrative liability.

3. Appeal to the Court of Appeals:

   • RBSM filed a motion for reconsideration, which was dismissed in a letter dated July 31, 2000. RBSM then appealed to the Court of Appeals (CA) via a petition for review under Rule 43 of the Rules of Court. The CA reversed and set aside the Monetary Board's resolution, finding the BSP officials administratively liable.

4. Petition to the Supreme Court:

   • The BSP and the Monetary Board filed a petition for review on certiorari before the Supreme Court, challenging the CA's decision. They argued, among other things, that RBSM had no legal remedy from the dismissal of its complaint, that RBSM failed to exhaust administrative remedies, and that the CA erred in holding the BSP officials administratively liable.

5. Parallel Proceedings:

   • A separate petition was filed by the BSP officials (Reyes, Domo-Ong, and Principio) in G.R. No. 154499, which was decided by the Supreme Court on March 14, 2003. The Court affirmed the CA's decision with modifications, finding Reyes and Domo-Ong administratively liable but absolving Principio.

6. Forum Shopping Allegations:

   • RBSM later moved to dismiss the petition in the present case, alleging that the BSP and Monetary Board were guilty of forum shopping. The Supreme Court denied the motion for consolidation of the two cases, as the decision in G.R. No. 154499 had already become final.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Improper Impleading of Agencies:

   • Under Section 6, Rule 43 of the Rules of Court, courts or agencies should not be impleaded as parties in a petition for review. The BSP and Monetary Board were improperly included as respondents in RBSM's petition before the CA.

2. Nominal Parties:

   • Since no relief was granted against the BSP and Monetary Board, they were treated as nominal parties, and their inclusion in the case was unnecessary.

3. Distinct Issues and Representation:

   • The issues raised by the BSP and Monetary Board in the present petition were distinct from those raised by the BSP officials in G.R. No. 154499. The parties were represented by different counsels, and there was no intent to forum shop.

4. Finality of Administrative Liability Issues:

   • The Supreme Court's decision in G.R. No. 154499 had already resolved the administrative liability of the BSP officials, and no further action on those issues was necessary.

Dispositive Portion

The Supreme Court PARTLY GRANTED the petition, excluding the BSP and the Monetary Board as respondents in the case. No costs were awarded.