Case Digest (G.R. No. 201199)
Facts:
- The case involves Steel Corporation of the Philippines (SCP) as the petitioner and several insurance companies as respondents: Mapfre Insular Insurance Corporation, New India Assurance Company Limited, Philippine Charter Insurance Corporation, Malayan Insurance Co., Inc., and Asia Insurance Phil. Corp.
- SCP, a domestic corporation manufacturing cold-rolled and galvanized steel, faced financial difficulties and was placed under corporate rehabilitation by the Regional Trial Court (RTC) on September 12, 2006.
- Atty. Santiago T. Gabionza, Jr. was appointed as the rehabilitation receiver.
- SCP had a Mortgage Trust Indenture (MTI) with the Bank of the Philippine Islands (BPI), requiring asset insurance until loans were fully paid.
- Following a fire on June 8, 2008, SCP received $450,000 in insurance proceeds, which BPI withheld.
- SCP sought the release of these funds for machinery repairs, but the RTC's order was contested by BPI and reversed by the Court of Appeals.
- Another fire on December 7, 2009, led SCP to file a motion on December 17, 2010, requesting $28,000,000 for property damage and $8,000,000 for business interruption from the insurers.
- The insurers contested the RTC's jurisdiction, claiming SCP did not comply with policy terms and that the claims were outside the rehabilitation court's jurisdiction.
- On June 1, 2011, the RTC ruled in favor of SCP, ordering the insurers to pay the claimed amounts.
- The insurers filed a petition for certiorari with the Court of Appeals, which ruled on February 8, 2012, that the RTC's order was void due to lack of jurisdiction.
- SCP's motion for reconsideration was denied on March 27, 2012, leading to the current petition for review on certiorari.
Issue:
- (Unlock)
Ruling:
- The Supreme Court denied SCP's petition and affirmed the Court of Appeals' February 8, 2012 Decision and March 27, 2012 Resolution, holding that the RTC lacked jurisdic...(Unlock)
Ratio:
- The Supreme Court reasoned that the Court of Appeals correctly determined that the RTC, acting as a rehabilitation court, did not have jurisdiction over SCP's claims against the insurers.
- Rehabilitation proceedings are summary ...continue reading
Case Digest (G.R. No. 201199)
Facts:
The case involves Steel Corporation of the Philippines (SCP) as the petitioner and several insurance companies—Mapfre Insular Insurance Corporation, New India Assurance Company Limited, Philippine Charter Insurance Corporation, Malayan Insurance Co., Inc., and Asia Insurance Phil. Corp.—as respondents. The events leading to the case began when SCP, a domestic corporation engaged in manufacturing and distributing cold-rolled and galvanized steel sheets and coils, faced financial difficulties and was placed under corporate rehabilitation by the Regional Trial Court (RTC) on September 12, 2006. The RTC appointed Atty. Santiago T. Gabionza, Jr. as the rehabilitation receiver. SCP had previously entered into a Mortgage Trust Indenture (MTI) with the Bank of the Philippine Islands (BPI), which required SCP to insure its assets until its loans were fully paid. Following a fire incident on June 8, 2008, SCP received $450,000 in insurance proceeds, which BPI, as the trustee, withheld. SCP sought the release of these funds to repair its damaged machinery, but the RTC's order to release the funds was contested by BPI and later reversed by the Court of Appeals.
On December 7, 2009, another fire damaged SCP's plant, prompting SCP to file a motion on December 17, 2010, requesting the RTC to direct the respondent insurers to pay $28,000,000 for property damage and $8,000,000 for business interruption. The insurers contested the RTC's jurisdiction over the...