A.C. No. 10612 - Saludares vs. Saludares

On January 20, 1999, the Spouses Roberto and Heidi L. Santos (Sps. Santos) filed a Complaint for Rescission of Sale and Real Estate Mortgage with Prayer for Injunction before the Regional Trial Court (RTC) of General Santos City, Branch 36, docketed as Civil Case No. 6492.
The Complaint was directed against Engr. Edgardo Torcende and Prime Savings Bank.

On January 7, 2000, during the pendency of Civil Case No. 6492, the Bangko Sentral ng Pilipinas (BSP) issued Resolution No. 22, prohibiting Prime Savings Bank from operating and placing it under receivership with the Philippine Deposit Insurance Corporation (PDIC) as the designated receiver.
On April 27, 2000, through Resolution No. 664, the BSP further placed Prime Savings Bank under liquidation, retaining PDIC as the appointed liquidator.
On July 19, 2000, pursuant to Section 30 of Republic Act No. 7653 (the New Central Bank Act), PDIC filed a Petition for Assistance in the Liquidation (PAL) of Prime Savings Bank before the RTC of Pasig City, designated as Special Proceeding Case No. 11097.

On September 1, 2006, the RTC rendered a Decision in favor of the Sps. Santos against both Engr. Torcende and Prime Savings Bank in Civil Case No. 6492.
On March 21, 2007, Prime Savings Bank received a Notice of Garnishment accompanied by the Entry of Final Judgment (February 13, 2007) and a subsequent Writ of Execution (February 14, 2007).
Prime Savings Bank moved to lift the garnishment order, arguing that as an institution under receivership or liquidation its assets were in "custodia legis" and exempt from such judicial orders pursuant to Section 30 of RA 7653.
On August 16, 2007, the RTC, finding merit in this position, issued an Order lifting the Writ of Execution and Notice of Garnishment.
The Sps. Santos, disagreeing with the RTC’s order, filed a Motion for Reconsideration.
On September 29, 2009, the RTC reversed its earlier order and granted the motion, thereby allowing the enforcement of the garnishment orders.
Consequently, on November 3, 2009, Prime Savings Bank received another Notice of Garnishment dated October 26, 2009 from the RTC’s sheriff.

On December 19, 2009, Prime Savings Bank filed a Petition for Certiorari under Rule 65 before the Court of Appeals (CA) in CA-G.R. SP No. 03348-MIN, seeking reversal of the RTC’s Order and the lifting of the garnishment measures.
On February 16, 2012, the CA issued the first Resolution denying the application for a Temporary Restraining Order (TRO) and/or Writ of Preliminary Injunction (WPI) as part of the Certiorari Petition.
Following a Motion for Reconsideration filed on March 9, 2012 by Prime Savings Bank, the CA reiterated its decision through a second Resolution denying the petition.
Subsequent pleadings included a Comment by the Sps. Santos on August 1, 2014, and a Reply by Prime Savings Bank on July 13, 2015.
The Certiorari Petition progressed, with the CA eventually rendering decisions that favored Prime Savings Bank in its main case concerning the enforcement of the garnishment orders.

On September 11, 2013, Prime Savings Bank, represented by its Statutory Liquidator, the PDIC, filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, challenging the CA’s interlocutory orders denying its ancillary application for TRO and/or WPI.
Later appeals, including those by the Sps. Santos in a separate proceeding (G.R. No. 226193), were dismissed, and the Certiorari Petition was eventually decided with finality in favor of Prime Savings Bank on July 29, 2015, with a subsequent Resolution dated June 21, 2016.

Whether the Court of Appeals was correct in denying Prime Savings Bank’s application for a Temporary Restraining Order (TRO) and/or Writ of Preliminary Injunction (WPI) as ancillary relief to its Certiorari Petition.
Whether the filing of a Petition for Review on Certiorari under Rule 45 was the proper remedy, given that the challenged CA Resolutions were interlocutory orders and not final judgments or orders.