G.R. No. 233463 - People vs. XXX

Peter L. So opened an account with the Cooperative Rural Bank Bulacan (CRBB) on April 17, 2013, with a deposit of P300,000.
He was assigned the Special Incentive Savings Account (SISA) No. 05-15712-1.

Later in 2013, CRBB closed its operations and was placed under the receivership of the Philippine Deposit Insurance Corporation (PDIC).
In response, petitioner and other depositors filed an insurance claim with the PDIC on November 8, 2013.

On November 22, 2013, the PDIC issued a notice requiring petitioner to submit additional documents, which he asserted he had complied with.
The PDIC discovered that petitioner’s account was derived from funds originating in a terminated SISA (the “mother account”), which was jointly owned by the Reyes family.
Based on the finding that his account was a product of the splitting of deposits—a practice prohibited by law—the PDIC denied his claim for deposit insurance.

Petitioner filed a Request for Reconsideration with the PDIC, which was denied on January 6, 2016.
Petitioner then elevated the matter by filing a Petition for Certiorari under Rule 65 before the Regional Trial Court (RTC) of Makati, Branch 138.
The RTC, in its decision dated November 7, 2016, upheld the PDIC’s factual findings and rationalized that the PDIC, by virtue of its Charter (RA 3591) and its quasi-judicial functions, was the proper authority to determine the validity of deposit insurance claims.
The RTC concluded that if a petition involves acts of a quasi-judicial agency, such as the PDIC, the proper venue is the Court of Appeals (CA) under Section 4, Rule 65.
Citing Section 22 of RA 3591, which stipulates that only the CA may issue temporary restraining orders or injunctions against PDIC, the RTC dismissed the petitioner’s certiorari petition for lack of jurisdiction.
On February 17, 2017, the RTC also denied petitioner’s motion for reconsideration.

Petitioner contended that the PDIC was not a quasi-judicial agency but rather a fact-finding body without any quasi-judicial power under its Charter, arguing for RTC jurisdiction over his petition.
He invoked the provisions of Section 4, Rule 65 (as amended by A.M. No. 07-7-12-SC) and referred to the Judiciary Reorganization Act (Batas Pambansa Blg. 129) to support his contention that multiple courts, including the RTC, could have concurrent jurisdiction over such petitions.

The applicability of Section 4, Rule 65 regarding the venue when challenging acts of a corporation or lower courts.
Section 22 of PDIC’s Charter, as amended, which restricts the issuance of injunctions against PDIC to the Court of Appeals.
Subsequent amendments under RA 10846 reinforcing that PDIC’s actions are final and executory, subject only to review by the CA on grounds of grave abuse of discretion or excess of jurisdiction.

Does the RTC have jurisdiction over a petition for certiorari filed under Rule 65 assailing the PDIC’s denial of a deposit insurance claim?
Is the proper remedy for challenging the PDIC’s decision exclusively within the ambit of the Court of Appeals due to PDIC’s quasi-judicial nature?

Whether the PDIC is a quasi-judicial agency empowered by its Charter to make final determinations on deposit insurance claims.
Whether its actions, being final and executory, can only be reviewed on a petition for certiorari filed within the prescribed period and before the appropriate court.

Does the legislative intent, as embedded in both the PDIC Charter and the Rules of Court, confirm that petitions involving acts or omissions of a quasi-judicial agency should be filed with the Court of Appeals rather than the RTC?