Case Digest (G.R. No. L-30511) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Manuel M. Serrano vs. Central Bank of the Philippines and Overseas Bank of Manila (G.R. No. L-30511, February 14, 1980), petitioner Manuel M. Serrano sought, by way of original action in the Supreme Court, writs of mandamus and prohibition, and a preliminary injunction against respondents Central Bank of the Philippines and Overseas Bank of Manila (including certain stockholders). Serrano alleged that he had made two time deposits with Overseas Bank—₱150,000 on October 13, 1966, and, by assignment from Concepcion Maneja, ₱200,000 on August 31, 1968—each for one year at agreed interest rates, yet the bank refused all demands for encashment from December 1967 to March 1968. He charged the Central Bank with failure to exercise a most stringent supervision over the distressed Overseas Bank, thus breaching its duty to protect depositors and to prevent misuse of depositors’ funds as collateral for the bank’s overdrafts and emergency loans. Serrano also sought a declaration of a con Case Digest (G.R. No. L-30511) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Time Deposits and Assignment
- On October 13 and December 12, 1966, petitioner Manuel M. Serrano placed time deposits of ₱150,000.00 (one year, 6% interest) with Overseas Bank of Manila.
- On March 6, 1967, Concepcion Maneja (wife of Felixberto M. Serrano) placed a time deposit of ₱200,000.00 (one year, 6½% interest) with the same bank.
- Assignment and Demands for Payment
- On August 31, 1968, Concepcion Maneja assigned her ₱200,000.00 time deposit to petitioner Serrano.
- Despite demands dated December 6, 1967 to March 4, 1968, Overseas Bank of Manila refused to honor any of the time deposit certificates.
- Central Bank Supervision and Prior Proceedings
- By Monetary Board Resolution No. 322 (March 12, 1965), Central Bank prohibited Overseas Bank from new loans and investments due to chronic reserve deficiencies; the restriction remained until 1968.
- No formal declaration of insolvency was made against Overseas Bank in 1966–1967; Central Bank maintained that it is not guarantor of bank solvency.
- In G.R. No. L-29352 (Emerito M. Ramos, et al. vs. Central Bank), petitioner Serrano sought to intervene but was denied; the Supreme Court ultimately annulled Central Bank resolutions ordering Overseas Bank’s liquidation and directed compliance with a Voting Trust Agreement.
- Present Petition
- Serrano filed for mandamus, prohibition, and a preliminary injunction to compel Central Bank, Overseas Bank, and its stockholders to pay the combined ₱350,000.00 with interest, establish joint and solidary liability, create a trust fund over collateral properties (Annex “7” of CBP’s answer in L-29352), and prohibit acts predicated on certain mortgages or transfers.
- This Court denied the ex parte application for preliminary injunction.
Issues:
- Whether mandamus and prohibition are proper remedies to recover time deposits with interest from Overseas Bank of Manila and to compel Central Bank to pay or secure such deposits.
- Whether Central Bank’s supervisory duty creates a constructive trust over assets mortgaged or assigned by Overseas Bank for the benefit of depositors.
- Whether the properties listed in Annex “7” constitute trust funds enforceable in this petition.
- Whether claims for recovery of deposits and damages against Central Bank belong in this Court’s original special proceedings or in ordinary courts/liquidation proceedings.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)