Title
Philippine Veterans Bank Employees Union vs. Vega
Case
G.R. No. 105364
Decision Date
Jun 28, 2001
Liquidation of Philippine Veterans Bank halted by R.A. 7169; Supreme Court ruled rehabilitation supersedes liquidation, rendering court functus officio.

Case Digest (G.R. No. 105364)

Facts:

Philippine Veterans Bank Employees Union-N.U.B.E. and Perfecto V. Fernandez v. Honorable Benjamin Vega, Presiding Judge of Branch 39 of the Regional Trial Court of Manila, the Central Bank of the Philippines and the Liquidator of the Philippine Veterans Bank, G.R. No. 105364, June 28, 2001, First Division, Kapunan, J., writing for the Court.

In 1985 the Central Bank of the Philippines filed with Branch 39 of the Regional Trial Court (RTC), Manila, a Petition for Assistance in the Liquidation of the Philippine Veterans Bank (PVB), docketed as Civil Case No. SP-32311. The Philippine Veterans Bank Employees Union-N.U.B.E., represented by Perfecto V. Fernandez (petitioners), filed claims in that liquidation for accrued and unpaid wages and benefits. Proceedings produced partial payments, but many employee claims remained unpaid after piecemeal hearings.

On March 8, 1991 petitioners moved to disqualify the respondent RTC judge for alleged bias. Meanwhile, on January 2, 1992 Congress enacted Republic Act No. 7169 providing for the rehabilitation of PVB and its reopening; the law was published in the Official Gazette on February 24, 1992. Petitioners then filed residual claims with labor tribunals seeking benefits and reinstatement upon reopening. In March 1992 PVB filed a Motion to Terminate Liquidation (March 13, 1992). The Monetary Board approved the Rehabilitation Plan (Monetary Board Resolution No. 348, April 10, 1992) and issued a Certificate of Authority allowing PVB to reopen; the liquidator also moved to terminate liquidation (June 3, 1992). PVB reopened to the public on August 3, 1992.

Despite the rehabilitative statute and subsequent Monetary Board approvals, the respondent RTC judge continued liquidation proceedings and issued orders involving acts of liquidation. Petitioners sought relief in this Court by filing a Petition for Prohibition with Petition for Preliminary Injunction and application for Ex Parte Temporary Restraining Order (Rule 65 relief). The Court issued a TRO on June 8, 1992 enjoining the trial court from further proceeding. VOP Security & Detective Agency and 162 guards moved to intervene and sought exclusion from the TRO; PVB filed a...(Pro-only)

Issues:

  • May the liquidation court continue with liquidation proceedings of the Philippine Veterans Bank after Congress enacted Republic Act No. 7169 mandating the bank’s rehabilitation and...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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