Facts:

The case is a Petition for Review on Certiorari filed by the Bank of the Philippine Islands (BPI) against respondents Marciano S. Bacalla, Jr., Eduardo M. Abacan, Erlinda U. Lim, Felicito A. Madamba, and Pepito M. Delgado. The case arises from the July 27, 2015 Decision and the March 4, 2016 Resolution of the Court of Appeals (CA) which upheld the Orders of the Regional Trial Court (RTC) of Las Piñas City, Branch 197, dated August 10, 2012 and January 14, 2013. The RTC had refused to apply the Interim Rules of Procedure for Intra-Corporate Controversies and denied BPI’s Request for Admission. The matter originated from a Petition for Involuntary Dissolution against the Tibayan Group of Investment Companies, Inc. (TGICI) filed in the RTC, which was decided in favor of the petitioners on September 24, 2004. Atty. Marciano S. Bacalla was appointed receiver and ordered to proceed with the liquidation of TGICI's assets. Respondents, acting alongside Bacalla and the Federation of

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Facts:

Background of the Case

• The petitioner, Bank of the Philippine Islands (BPI), filed a Petition for Review on Certiorari challenging lower court decisions.
• The Petition for Review sought to assail the July 27, 2015 Decision and March 4, 2016 Resolution of the Court of Appeals (CA) in CA-G.R. SP No. 129574.
• The case originates from a Petition for Involuntary Dissolution of Tibayan Group of Investment Companies, Inc. (TGICI) filed before the Regional Trial Court (RTC), Branch 253.
• On September 24, 2004, the RTC granted the petition, ordering the dissolution of TGICI and several related corporations and directing the receiver, Atty. Marciano S. Bacalla, Jr., to liquidate the properties pursuant to Sections 121 and 122 of the Corporation Code.

Subsequent Proceedings and Related Actions

• Acting in his capacity as receiver, Atty. Bacalla, together with TGICI investors (respondents Eduardo M. Abacan, Erlinda U. Lim, Felicito A. Madamba, and Pepito M. Delgado) and the Federation of Investors Tulungan, Inc. (FITI), initiated Civil Case No. LP-05-0212 alleging fraud and misrepresentations involving TGICI.
• The complaint alleged that TGICI employed fraudulent inducements, deceit, and misrepresentations to solicit deposits and investments by representing itself as duly licensed by the SEC.
• It further alleged the diversion of funds and improper share transactions, including the purchase of common shares in Prudential Bank by Cielo Azul using proceeds allegedly generated by fraudulent activity.
• During pre-trial, BPI moved to declare certain respondents as non-suited on the ground that they lacked Special Powers of Attorney. This motion was denied by the RTC.
• Petitioner later filed a series of Requests for Admissions which, among other assertions, reiterated the respondents’ lack of Special Powers of Attorney and related knowledge about other proceedings involving Cielo Azul.

Procedural History

• The RTC rendered orders denying the petitioner’s motions, including a November 28, 2011 Order and an August 10, 2012 Order denying both the motion to declare respondents as non-suited and the Requests for Admissions.
• Dissatisfied with these orders, the petitioner filed a Petition for Certiorari before the CA (docketed CA-G.R. SP No. 127072) as well as later filing another petition (CA-G.R. No. 129574) focused on the application of the Interim Rules.
• The CA, in its July 27, 2015 Decision and subsequent March 4, 2016 Resolution, denied the petitioner’s petitions by upholding that:
• The respondents’ complaint involved an intra-corporate controversy falling under Section 5(a) of P.D. No. 902-A.
• The petitioner was guilty of splitting its cause of action and that its remedy had already prescribed.
• The petitioner contended that the application of the Interim Rules for Intra-Corporate Controversies was improper and that the rule against splitting a cause of action was misapplied.

Issue:

Applicability of the Interim Rules

• Whether the Interim Rules of Procedure for Intra-Corporate Controversies under R.A. No. 8799 applies to the proceedings in the RTC.
• Whether the allegations in the respondents’ complaint sufficiently establish an intra-corporate controversy based on both the relationship test and the nature of the controversy test.

Splitting of the Cause of Action

• Whether the petitioner is guilty of splitting its cause of action by filing separate certification petitions regarding different aspects (non-suit and application of the Interim Rules).
• Whether the rule against splitting a cause of action applies to a Petition for Certiorari which is predicated on the existence of alleged grave abuse of discretion rather than an underlying cause of action.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)