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....

Facts:

Background of the Case

• Petitioner: Steel Corporation of the Philippines (SCP), a domestic corporation engaged in manufacturing and distributing cold-rolled and galvanized steel sheets and coils.
• Respondents: Mapfre Insular Insurance Corporation, New India Assurance Company Limited, Philippine Charter Insurance Corporation, Malayan Insurance Co., Inc., and Asia Insurance Phil. Corp. (collectively referred to as "respondent insurers").
• Loans and Mortgages: SCP obtained loans from several creditors and mortgaged its assets as security. Bank of the Philippine Islands (BPI) was appointed as the trustee for the creditors.
• Mortgage Trust Indenture (MTI): SCP and BPI entered into an MTI on 17 December 1997, requiring SCP to insure its assets until the loans were fully paid. The insurance policies were to be made payable to BPI.

Financial Difficulties and Rehabilitation

• Rehabilitation Petition: On 11 September 2006, one of SCP's creditors, Equitable PCI Bank, filed a petition to place SCP under corporate rehabilitation. The Regional Trial Court (RTC) issued a stay order on 12 September 2006, deferring all claims against SCP and appointing a rehabilitation receiver.
• Approval of Rehabilitation Plan: On 3 December 2007, the RTC approved a modified rehabilitation plan for SCP.

First Fire Incident (2008)

• Insurance Policy: SCP insured its assets under Collective Master Policy No. UCPB Gem HOF075089 for the period 19 August 2007 to 19 August 2008.
• Fire Damage: On 8 June 2008, a fire broke out at SCP's plant, damaging its machineries. BPI, invoking the MTI, received $450,000 in insurance proceeds from the insurers.
• Motion to Release Funds: On 13 October 2009, SCP filed a motion with the RTC to direct BPI to release the $450,000 insurance proceeds to repair and replace the damaged machineries. The RTC granted the motion on 5 January 2010, but the Court of Appeals reversed this decision on 3 October 2012, holding that BPI was entitled to hold the insurance proceeds in trust.

Second Fire Incident (2009)

• Insurance Policy: SCP insured its assets under Industrial All Risks Insurance Policy No. F-369430 for the period 19 August 2009 to 19 August 2010.
• Fire Damage: On 7 December 2009, another fire broke out at SCP's plant, damaging its cold rolling mill and other machineries.
• Insurance Claim: On 17 December 2010, SCP filed a motion with the RTC to direct respondent insurers to pay $28,000,000 for property damage and $8,000,000 for business interruption.
• Insurers' Defense: Respondent insurers denied liability, citing several grounds, including SCP's failure to comply with policy terms, fraud, over-insurance, and negligence.

RTC's Ruling

• Order to Pay: On 1 June 2011, the RTC granted SCP's motion and ordered respondent insurers to pay $33,882,393 for property damage and $8,000,000 for business interruption. The RTC held that it had jurisdiction over the insurance claims as part of the rehabilitation proceedings.

Issue:

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Ruling:

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Ratio:

1. Jurisdiction of Rehabilitation Courts: Rehabilitation courts have limited jurisdiction over claims against the debtor, not claims by the debtor against third parties. SCP's insurance claims against respondent insurers are not within the jurisdiction of the rehabilitation court.
2. Proper Remedy: A petition for certiorari under Rule 65 is the proper remedy when the issue involves errors of jurisdiction, as in this case where respondent insurers questioned the RTC's jurisdiction over the insurance claims.
3. Nature of Rehabilitation Proceedings: Rehabilitation proceedings are summary and non-adversarial, designed to resolve claims quickly and expeditiously. Claims requiring a full trial on the merits, such as SCP's insurance claims, must be resolved in a separate action.

Conclusion:

The Supreme Court denied SCP's petition, affirming the Court of Appeals' decision that the RTC lacked jurisdiction over SCP's insurance claims against respondent insurers. SCP must file a separate action to recover its claims.