G.R. No. 157216 - 246 Corp. vs. Daway

Background of the Escheat Proceedings
The case arises from the implementation of Act No. 3936, known as the Unclaimed Balance Law, which mandates that banks forward statements of dormant deposits (those inactive for ten or more years) to the Treasurer of the Philippines.
In January 1968, 31 banks, including Pres. Roxas Rural Bank, submitted sworn statements under oath listing dormant deposits. In the sworn statement of the private respondent bank, only two accounts were listed:

Publication and Filing of the Complaint
The Treasurer published the sworn statements in the "Philippines Herald" (English) and "El Debate" (Spanish) on February 25, March 3, and March 10, 1968.
On July 25, 1968, the Republic of the Philippines instituted escheat proceedings before the Court of First Instance (CFI) of Manila, Branch XIII.
The complaint, titled “Republic of the Philippines vs. Bank of America, et al.,” included as defendants not only the 31 banks but also the individual depositors/creditors reported in the statements as set forth in Annex “A”.
Summonses were issued to require the banks and the identified depositors/creditors to file their answers within 60 days following the first publication of the summons, with a warning of default judgment should they fail to respond.
The summons and complaint were again published in the "Philippines Herald" and "El Debate" on August 25, September 1, and September 8, 1968.

Motion to Dismiss and Subsequent Proceedings
On October 5, 1968, Pres. Roxas Rural Bank filed a motion to dismiss its inclusion in the complaint on the ground of improper venue.
The Court of First Instance granted the motion to dismiss against the bank.
A motion for reconsideration of the dismissal following the first order was submitted by the petitioner but was denied in a subsequent order dated March 1, 1969.
The petition by certiorari was then filed on pure questions of law concerning:

Whether the bank is a real party in interest in such escheat proceedings.
The appropriateness of the venue in the CFI of Manila given statutory guidelines.
The applicability of Section 2(b), Rule 4 of the Revised Rules of Court on venue in escheat proceedings.

Real Party in Interest
Whether Pres. Roxas Rural Bank qualifies as a real party in interest in the escheat proceedings despite the fact that the dormant deposits ultimately benefit the government.
If the bank, by virtue of being deprived of its dormant deposits upon escheat, is entitled to assert motions such as dismissal on procedural grounds.

Proper Venue of Action
Whether the venue established in the Court of First Instance of Manila is proper under Act No. 3936, considering the statutory requirement that actions be brought in the province or city where the bank is located.
Whether the inclusion of all banks in one single suit, regardless of their geographic location, is consistent with legislative intent and statutory provision.

Applicability of Revised Rules on Venue
Whether Section 2(b) of Rule 4 of the Revised Rules of Court can govern escheat proceedings which are in rem rather than personal actions.