Case Digest (G.R. No. 179054) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Carlito B. Linsangan vs. Philippine Deposit Insurance Corporation, petitioner Carlito B. Linsangan filed a claim for deposit insurance after the Bangko Sentral ng Pilipinas’ Monetary Board ordered the closure of Cooperative Rural Bank of Bulacan, Inc. (CRBBI) on May 23, 2013 and placed it under the PDIC’s receivership. At the time, petitioner’s Special Incentive Savings Account (SISA) No. 00-44-10750-9 showed a balance of ₱400,000. PDIC’s investigation revealed that this account originated from a source account in the names of Cornelio and Ligaya Linsangan, which was closed on December 13, 2012 with a balance of ₱1,544,081.48 and split into four accounts, including petitioner’s. Applying PDIC Regulatory Issuance No. 2009-03, PDIC concluded petitioner was neither a qualified relative of the transferors nor able to prove valid consideration by documents in the bank’s records, and thus consolidated the resulting accounts for purposes of computing insured deposits. On July 12, 20 Case Digest (G.R. No. 179054) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Closure and Receivership
- On May 23, 2013, the Monetary Board of the BSP ordered the closure of Cooperative Rural Bank of Bulacan, Inc. (CRBBI) and placed it under PDIC receivership.
- PDIC took over CRBBI’s assets and examined its records to determine insured deposits.
- Petitioner’s Claim and PDIC’s Investigation
- Petitioner Carlito B. Linsangan filed a claim for deposit insurance on his Special Incentive Savings Account (SISA) No. 00-44-10750-9 with a balance of ₱400,000 at closure.
- PDIC traced the funds to a source account in the names of Cornelio and Ligaya Linsangan, which held ₱1,531,993.42 on opening and ₱1,544,081.48 at closure.
- On December 13, 2012, the source account was split and its balance distributed to four accounts, including petitioner’s.
- PDIC found no documents in CRBBI’s records proving valid consideration for the transfer to petitioner, nor that petitioner was a qualified relative (second degree consanguinity or affinity) of the transferors.
- Pursuant to PDIC Regulatory Issuance No. 2009-03, PDIC treated Cornelio and Ligaya as the beneficial owners and consolidated the resulting accounts for insurance purposes, limiting coverage to ₱500,000 per depositor.
- Administrative and Judicial Proceedings
- July 12, 2013 – PDIC denied petitioner’s insurance claim; August 6, 2014 – request for reconsideration denied.
- Petitioner filed a petition for certiorari with the Court of Appeals (CA), which on March 31, 2016 affirmed PDIC’s denial; December 19, 2016 – CA denied reconsideration.
- Petitioner elevated the case to the Supreme Court via a petition for review on certiorari.
Issues:
- Whether PDIC correctly applied PDIC Regulatory Issuance No. 2009-03 in determining beneficial ownership and denying petitioner’s deposit insurance claim.
- Whether the transfer of funds occurring more than 120 days before bank closure exempts petitioner from proving valid consideration and documentary proof in bank records.
- Whether petitioner, as a purported donee, is entitled to deposit insurance coverage absent documents evidencing the donation in the bank’s custody.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)