Case Digest (G.R. No. 234401) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Connie L. Servo v. Philippine Deposit Insurance Corporation, Petitioner Connie L. Servo alleged that in October 2011 she lent Teresita Guiterrez Five Hundred Thousand Pesos (₱500,000.00) for bus repairs and met Guiterrez on January 19, 2012 at the Rural Bank of San Jose Del Monte to receive payment. To facilitate this transaction, Petitioner opened a time deposit under Special Savings Deposit Account No. 001-03-00904-1 in Guiterrez’s name, with an agreement that the funds were held in trust for her. When the bank later closed, Petitioner filed an August 22, 2014 claim for deposit insurance with Respondent PDIC, asserting sole ownership of the account and submitting supporting documents. PDIC denied the claim by letter dated August 27, 2014 for lack of proof that Petitioner, rather than Guiterrez, owned the account and denied her Request for Reconsideration on July 16, 2015 for failure to prove a valid consideration. On August 19, 2016, Petitioner filed a special civil action ... Case Digest (G.R. No. 234401) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Loan and Deposit Arrangement
- October 2011 – Petitioner Connie L. Servo lent Teresita Guiterrez ₱500,000 for bus repairs; funds placed in trust.
- January 19, 2012 – Petitioner opened Special Savings Deposit (SSD) Account No. 001-03-00904-1 at Rural Bank of San Jose del Monte under Guiterrez’s name per their agreement.
- PDIC Claim and Denial
- August 22, 2014 – Petitioner filed a deposit insurance claim with PDIC after the bank’s closure, asserting exclusive ownership of the SSD account.
- August 27, 2014 & July 16, 2015 – PDIC denied the claim and reconsideration request for lack of documents proving ownership and valid consideration in the fund transfer.
- Judicial Proceedings
- August 19, 2016 – Petitioner filed a special civil action for certiorari in the RTC, alleging grave abuse of discretion by PDIC; RTC dismissed for lack of jurisdiction, citing PDIC’s quasi-judicial character and RA 3591, § 5(g).
- September 22, 2017 – On certiorari, the Court of Appeals dismissed the petition for lack of jurisdiction, ruling that pure questions of law belong to the Supreme Court under Rule 45.
- December 5, 2019 – Petitioner elevated the case to the Supreme Court via petition for review on certiorari.
Issues:
- Did the Court of Appeals err in dismissing the petition for certiorari on the ground of lack of jurisdiction?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)