Facts:

The case involves Bangko Silangan Development Bank (BSDB) as the petitioner and respondents Judge Pablo D. Atienza, in his capacity as Presiding Judge of Branch 14, Regional Trial Court, Fourth Judicial Region, Nasugbu, Batangas, and Leonida Umandal-Bausas, a saver at the bank. The events leading to this case commenced on April 23, 1990, when Leonida attempted to withdraw P5,000 from her savings account at BSDB, from which she had previously deposited P15,000. However, she was informed by the bank teller that all her money had already been withdrawn by her brother, Antonio Umandal, allegedly with her written authorization. Shocked, Leonida realized that the signature on the withdrawal slip was neither hers nor that of her brother's. Following this, she sought the assistance of Edmundo Villadolid, a family friend, who wrote to BSDB regarding this unauthorized withdrawal.

BSDB conducted an internal investigation, which concluded that proper procedures were followed for the wit

...

Facts:

Party Background and Account Details

• Petitioner Bangko Silangan Development Bank (BSDB), Nasugbu Branch, Batangas, maintained a savings account (No. 04-3652) for respondent Leonida Umandal-Bausas since 1985.
• As of April 1990, the account held a balance of Fifteen Thousand Pesos (P15,000.00).

Unauthorized Withdrawal Incident

• On April 23, 1990, respondent Bausas attempted to withdraw P5,000.00, only to learn that P15,000.00 had allegedly been withdrawn earlier on April 16, 1990 by her brother, Antonio Umandal, using her savings passbook and a withdrawal slip bearing signatures allegedly from both her and her brother.
• Upon inspection, respondent Bausas discovered that the signatures on the withdrawal slip did not match her own or that of her brother, casting doubt on the legitimacy of the transaction.

Initial Complaint and the Role of Third Parties

• Dismayed by the unexpected withdrawal, respondent Bausas sought assistance from her family friend, Edmundo Villadolid, then President-Manager of the Rural Bank of Nasugbu, Batangas.
• On April 24, 1990, Villadolid sent BSDB a letter accompanied by an affidavit by respondent Bausas, alleging that the withdrawal involved “foul play” and constituted an unwarranted banking operation.

Internal Investigation and Bank’s Response

• In response to Villadolid’s letter, BSDB initiated an investigation through its auditor, Benedicto I. Ramirez, who in his report (dated May 4, 1990) affirmed that the withdrawal slip bore signatures which, according to bank procedures, were processed in accordance with the standard operating procedure.
• Despite the findings, conflicting testimony emerged as both respondent Bausas and her brother later denied having signed the withdrawal slip, thereby intensifying the controversy.

Escalation of the Dispute and Alternative Avenues

• On May 15, 1990, Villadolid escalated the matter by requesting the Central Bank of the Philippines to investigate BSDB’s handling of the complaint, which led to further correspondence between BSDB’s head office and the Central Bank.
• Subsequently, media involvement occurred when the case was publicized in the People’s Journal Tonight on September 17, 1990, highlighting the issue of bank money being withdrawn without the depositor’s knowledge.

Parallel Litigation and the Emergence of Two Civil Cases

• In Civil Case No. 91-56185 filed in the Regional Trial Court (RTC) of Manila, BSDB initiated a complaint for damages against respondent Bausas, Villadolid, and several media entities, alleging defamation and libel connected to the publications reporting the withdrawal.
• During the pendency of Civil Case No. 91-56185, respondent Bausas, joined by her husband, filed Civil Case No. 221 in the RTC of Batangas, Branch 14, seeking the retrieval of the withdrawn sum along with additional claims for litigation expenses and attorney’s fees.

Motion to Dismiss and Subsequent Judicial Proceedings

• Instead of filing a responsive pleading to Civil Case No. 221, petitioner BSDB filed a motion to dismiss, arguing that the case was barred by litis pendentia due to its resemblance to Civil Case No. 91-56185, among other claims such as forum-shopping and multiplicity of suits.
• The RTC of Batangas, on September 10, 1992, denied the motion to dismiss; a motion for reconsideration filed by BSDB was similarly denied on November 19, 1992.

Appellate Review and the Petition for Certiorari

• BSDB elevated the matter to the Court of Appeals via a petition for certiorari, prohibition, and mandamus, seeking the reversal of the RTC’s denial of its motion to dismiss on the grounds of litis pendentia and alleged grave abuse of discretion.
• On February 26, 1993, the Court of Appeals dismissed BSDB’s petition, holding that an order denying a motion to dismiss is interlocutory and not appealable, and clarified that the doctrine of litis pendentia was not applicable in this instance because the two civil cases involved distinct causes of action and reliefs.

Issue:

Interlocutory Nature of the Lower Court’s Order

• Whether an order denying the motion to dismiss (filed by BSDB) is interlocutory and therefore not subject to a petition for certiorari.
• Whether the proper remedy for BSDB would have been to await trial and then appeal an adverse final judgment rather than seek a certiorari relief.

Applicability of the Doctrine of Litis Pendentia

• Whether the presence of two civil cases (Civil Case No. 91-56185 and Civil Case No. 221) involving the same parties but different causes of action and reliefs fulfills the requirements for litis pendentia.
• Whether the splitting of related issues across two cases constitutes forum-shopping or an abuse of jurisdiction/discretion on the part of the RTC of Batangas.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)