G.R. No. 233850 - Trade and Investment Development Corporation of the Philippines vs. Philippine Veterans Bank

Petitioner: Trade and Investment Development Corporation of the Philippines (TIDCORP), also known as PhilEXIM; Respondent: Philippine Veterans Bank (PVB).
On November 23, 2011, PVB and other banks (Series A Noteholders) entered into a Five-Year Floating Rate Note Facility Agreement with Philippine Phosphate Fertilizer Corporation (PhilPhos) for up to P5 billion; PVB committed P1 billion.
To secure the Series A Notes, TIDCORP, with PhilPhos’ express conformity, executed a Guarantee Agreement dated November 23, 2011, under which TIDCORP guaranteed payment of 90% of the outstanding Series A Notes and interest on a rolling successive three-month basis from first drawdown until maturity, and expressly waived the benefit of excussion and any requirement of presentment, demand, protest, or notice.

On November 8, 2013, Typhoon Yolanda devastated Leyte where PhilPhos’ plant was located, causing it to cease operations.
On September 17, 2015, PhilPhos filed a Petition for Voluntary Rehabilitation under the FRIA (RA 10142) in RTC Ormoc, Branch 12; a Commencement Order with a Stay Order issued on September 22, 2015, staying claims, actions, or proceedings against PhilPhos.

On November 5, 2015 (within 45 days per the Guarantee Agreement), PVB filed a Notice of Claim with TIDCORP; TIDCORP received it on November 6, 2015.
By letter dated November 12, 2015, TIDCORP declined to process the claim, invoking the Rehabilitation Court’s Stay Order; it maintained this position despite PVB’s repeated demands.

On September 22, 2016, PVB filed a Complaint for Specific Performance against TIDCORP in RTC Makati, Branch 150 (Civil Case No. R-MKT-16-02011-CV), alleging TIDCORP’s waiver of excussion and solidary-like liability under the Guarantee Agreement.
TIDCORP’s Answer asserted the RTC’s lack of jurisdiction due to the Stay Order in the rehabilitation case and contested receipt/completeness of the Notice of Claim.
PVB moved for Summary Judgment (February 14, 2017); TIDCORP opposed.
On August 16, 2017, the RTC granted summary judgment for PVB, holding there was no genuine issue of material fact on TIDCORP’s liability under the Guarantee Agreement, except the amount of damages.

TIDCORP filed a Rule 45 Petition for Review on Certiorari (in relation to Rule 41, Sec. 2[c]), treating the RTC’s Order as a final judgment involving pure questions of law.
PVB moved to dismiss (wrong mode of appeal), claiming the Order was interlocutory; the Supreme Court denied the motion (September 12, 2018).
The case proceeded on the sole issue of whether the RTC correctly granted summary judgment.

Whether the RTC’s Order granting PVB’s Motion for Summary Judgment, which adjudicated liability but left the amount of damages for later determination, is a final order appealable by Rule 45.

The alleged lack of jurisdiction in view of the Rehabilitation Court’s Stay Order under the FRIA.
The alleged existence of genuine issues of material fact requiring trial.