Case Digest (G.R. No. 222972)
Facts:
Hermosa Savings and Loan Bank, Inc., represented by its statutory liquidator, Philippine Deposit Insurance Corporation (PDIC), petitioner, vs. Development Bank of the Philippines (DBP), respondent, G.R. No. 222972, August 06, 2025, Supreme Court Special Third Division, Inting, J., writing for the Court.In 2001 DBP filed a Complaint for Sum of Money and Damages (Civil Case No. 01-1438) against Hermosa Savings and Loan Bank, Inc. and several of its officers (Benjamin Cruz et al.) in the Regional Trial Court (RTC), Branch 136, alleging default on DBP-sourced IGLF loans, fraud in loan and collateral documents, and an outstanding balance of PHP 438,235,392.60; DBP sought a writ of preliminary attachment and money judgment. A writ of preliminary attachment issued November 13, 2001; it was later lifted (Oct. 14, 2003) and ultimately reinstated pursuant to a Court of Appeals (CA) decision in CA-G.R. SP No. 84762.
In February 2005 the Bangko Sentral ng Pilipinas (BSP) ordered the closure of Hermosa Bank and placed it under receivership; PDIC was appointed receiver. On June 7, 2005 PDIC filed a Petition for Assistance in the Liquidation (PAL) of Hermosa Bank, docketed as SP No. DH-025-05 before RTC Branch 5, Dinalupihan, Bataan (the liquidation court). After PDIC entered appearance in Civil Case No. 01-1438, defendants moved to dismiss for lack of jurisdiction, invoking the liquidation court’s competence under statutory provisions (notably Section 30 of R.A. No. 7653 and the PDIC Charter as amended).
RTC-Branch 136 first granted the motions to dismiss (Oct. 6, 2008), then on reconsideration reinstated the complaint (Mar. 18, 2009), and finally again dismissed the complaint for lack of jurisdiction (Order dated Apr. 30, 2010). The case was re-raffled to RTC-Branch 57 (family court designation), which denied DBP’s motion for reconsideration (Oct. 18, 2011), relying on PDIC Charter provisions deeming the bank’s assets in custodia legis and channeling claims to the liquidation court.
DBP appealed to the Court of Appeals. In its Decision dated February 26, 2015 (CA-G.R. CV No. 98170) the CA reversed the RTC Orders, holding that jurisdiction once acquired remains until termination, that matters against the officers could not be relegated to the liquidation court, and that DBP would be unduly prejudiced; the CA reinstated the writ of attachment. The CA denied motions for reconsideration in a February 15, 2016 Resolution.
Hermosa Bank filed a Petition for Review on Certiorari under Rule 45. In the assailed Decision dated February 10, 2021 the Supreme Court (Third Division) granted Hermosa’s petition, held that the liquidation court has exclusive jurisdiction over disputed claims against a closed bank, reinstated the RTC dismissal orders, and ordered dissolution of the writ of preliminary attachment. DBP moved for reconsideration before the Court, arguing among other points that Section 30 of the New Central Bank Act was amended by R.A. No. 11211 (allegedly removing the liquidation court’s exclusive adjudicatory role), that PDIC Charter provisions and R.A. No. 10846 permit continuation of pending suits, that the liqui...(Pro-only)
Issues:
- Did the Court err in ruling that the liquidation court has exclusive jurisdiction over all claims against a closed bank, including those that were the subject of prior pending cases?
- Can the liquidation court adjudicate and assist in enforcement of the personal liabilities of bank officers arising from a criminal offense?
- Should the writ of preliminary attachment issue...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)