Case Digest (G.R. No. 45130)
Facts:
In Bank of Commerce v. Planters Development Bank and Bangko Sentral ng Pilipinas, the Rizal Commercial Banking Corporation (RCBC) originally owned nine Central Bank (CB) bills issued in early 1994. Through a series of assignments and sales, the Planters Development Bank (PDB) acquired two bills (face value ₱20 million) on April 19, 1994, while the Bank of Commerce (BOC) ultimately acquired seven bills (face value ₱70 million) via an April 15, 1994 transaction. PDB retained the detached assignments as evidence of ownership, yet delivered the actual CB bills to BOC or its designees. As these bills changed hands—BOC sold and repurchased subsets from Bancapital and All-Asia—PDB notified the BSP’s Government Securities Department in June 1994 of alleged fraudulent transfers and sought annotation of its claim in BSP records under CB Circular No. 28. BSP, citing lack of possession and non-recorded assignment, refused. PDB then filed with the Regional Trial Court (RTC) of Makati two petCase Digest (G.R. No. 45130)
Facts:
- Case Background
- Two consolidated petitions (G.R. Nos. 154470-71 and 154589-90) under Rule 45 by Bank of Commerce (BOC) and Bangko Sentral ng Pilipinas (BSP) against Makati RTC Branch 143 orders dismissing Planters Development Bank’s (PDB) petitions and the counterclaims of BOC and BSP.
- PDB sought mandamus, prohibition and injunction to compel BSP to note PDB’s claim over nine Central Bank (CB) bills allegedly fraudulently assigned.
- Transactions Involving CB Bills
- First set (seven CB bills, P70 million face value issued Jan 2, 1994):
- RCBC sold to BOC; BOC sold to PDB; PDB agreed to sell Treasury bills but delivered CB bills as substitution.
- Subsequent re-transfers: three bills reacquired by BOC via Bancapital Dev. Corp.; four bills through Capital One, All-Asia and RCBC resulted in BOC acquiring all seven.
- Second set (two CB bills, P20 million face value issued Jan 3, 1994):
- RCBC sold to PDB with detached assignments; PDB delivered bills to Bancapital; bills ultimately sold to BOC.
- PDB’s Claim of Fraudulent Assignment
- PDB retained detached assignments and notified BSP (June 30, 1994) to record its claim under CB Circular No. 28 Sec. 10(d)(4) to bar payment to holders in due course.
- BSP refused, citing failure to present the bonds and record assignments in BSP books (CB Circular No. 28 Secs. 8, 10(b)(2)).
- RTC Proceedings and Interpleader
- PDB filed Civil Cases 94-3233 and 94-3254 for provisional injunctions, later consolidated; RTC granted preliminary injunctions enjoining BSP from payment.
- BOC and BSP impleaded, filed counterclaims: BOC asserted valid sale and good-faith acquisition; BSP moved for interpleader to determine rightful claimant.
- Parties entered escrow agreements depositing 50% of matured proceeds each; RTC approved and granted BSP’s motion to interplead, requiring claimants to substantiate claims.
- On PDB’s motion, RTC later dismissed PDB’s petitions, BOC’s counterclaims and BSP’s interpleader, ruling it lacked jurisdiction under CB Circular No. 28.
Issues:
- Governing Regulation and Jurisdiction
- Does CB Circular No. 769-80 (1993) impliedly repeal or amend CB Circular No. 28’s Sec. 10(d)(4) on fraudulent assignments of registered bonds?
- Under which circular and legal authority—BSP or RTC—must conflicting ownership claims to CB bills be adjudicated?
- Proper Remedy and Failure to Pay Fees
- Is interpleader the correct procedural remedy to resolve competing claims over CB bills?
- Must defendants-in-interpleader (BOC and PDB) pay docket fees for their claims in the interpleader proceeding?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)