Case Summary (G.R. No. 172454)
Key Dates
May 23, 2013
Closure of CRBBI by BSP and placement under PDIC receivership.
July 12, 2013
PDIC denial of petitioner’s deposit insurance claim.
August 6, 2014
PDIC denial of petitioner’s reconsideration.
March 31, 2016
Court of Appeals decision affirming PDIC.
December 19, 2016
Court of Appeals resolution denying reconsideration.
February 10, 2020
Supreme Court decision date.
Applicable Law
– 1987 Philippine Constitution (decision after 1990)
– Republic Act No. 3591 (PDIC Charter)
– PDIC Regulatory Issuance No. 2009-03 (rules on beneficial ownership and deposit splitting)
Factual Background
Upon BSP closure of CRBBI, petitioner claimed P400,000 on a SISA. PDIC’s records showed that this account originated from a “source account” held by Cornelio and Ligaya Linsangan with a balance exceeding the P500,000 insurance limit. The source account was closed on December 13, 2012, and its funds were divided among four accounts, including petitioner’s. PDIC traced beneficial ownership and concluded petitioner was neither a qualified relative nor could show valid transfer documentation.
PDIC’s Investigation and Ruling
Under its charter and Regulatory Issuance No. 2009-03, PDIC consolidated the four resulting accounts back to Cornelio and Ligaya for insurance computation. Lacking bank records evidencing a valid transfer or proof of qualified relationship, PDIC denied petitioner’s claim on July 12, 2013, and denied reconsideration on August 6, 2014.
Court of Appeals Ruling
The CA found no grave abuse of discretion. It held that PDIC properly scrutinized the splitting of deposits, noting suspicious timing and lack of documentation. The CA affirmed the denial of petitioner’s claim, emphasizing that PDIC’s action does not invalidate any alleged donation and that unpaid insured deposits may still be recovered from CRBBI’s assets.
Issues and Petitioner’s Contentions
- Transfer occurred more than 120 days before bank closure, so “deposit splitting” rules do not apply.
- He was not informed that transfer documents needed to be on file prior to PDIC takeover.
- Requiring bank custody of transfer documents violates due process and imposes extra requisites on donations.
Supreme Court’s Analysis on PDIC Authority
Under R.A. No. 3591, PDIC “shall grant or deny claims for deposit insurance” and aggregate all deposits maintained in the same right. The 1987 Constitution upholds procedural due process but does not require personal notice of universally published regulations.
Interpretation of Regulatory Issuance No. 2009-03
– Section III recognizes the registered owner as depositor entitled to insurance, except when records show multiple accounts maintained for the same beneficial owner.
– When a deposit exceeding the insurance limit is split into accounts, the transferor remains the beneficial owner unless the transferee proves: (a) valid consideration with supporting details in bank records, and (b) possession of transfer documents by the bank at takeover, or (c) qualified relative status (second degree of consanguinity or affinity).
Deposit Splitting vs. Transfers Outside the 120-Day Window
– Deposit Splitting (Section IV) presumes improper splitting when transfers occur within 120 days before closure, triggering criminal liability for bank personnel.
– Transfers prior to the 120-day period are not automatically insured unless the transferee proves valid consideration through existing bank records. In the absence of such documentation, p
Case Syllabus (G.R. No. 172454)
Antecedents
- On May 23, 2013, the Monetary Board of the Bangko Sentral ng Pilipinas ordered the closure of Cooperative Rural Bank of Bulacan, Inc. (CRBBI) and placed it under the receivership of PDIC.
- PDIC examined CRBBI’s records and assumed control of its assets to determine insured deposits.
- Petitioner Carlito B. Linsangan filed a claim for deposit insurance on his Special Incentive Savings Account (SISA) No. 00-44-10750-9, which showed a balance of ₱400,000 at closure.
- PDIC discovered that petitioner’s account was funded by a December 13, 2012 transfer from the joint account of Cornelio and Ligaya Linsangan, which had an original balance exceeding ₱1.53 million.
- The source account’s balance of ₱1,544,081.48 was split and distributed among four accounts, including that of petitioner.
- Under PDIC Regulatory Issuance No. 2009-03, par. V, and absent proof of valid consideration or qualified‐relative status, PDIC consolidated petitioner’s account with Cornelio and Ligaya’s deposits and capped insurance at ₱500,000 per depositor.
- On July 12, 2013, PDIC denied the claim; on August 6, 2014, it likewise denied reconsideration.
- Petitioner elevated the matter to the Court of Appeals via a petition for certiorari.
Court of Appeals Ruling
- In its March 31, 2016 Decision, the CA found no grave abuse of discretion by PDIC, holding that it properly applied existing regulations.
- The CA noted both petitioner and transferors failed to inform CRBBI of deposit splitting or provide supporting details.
- Indicators of a scheme to circumvent deposit insurance prompted PDIC’s scrutiny.
- The CA clarified that denial of deposit insurance does not invalidate an alleged donation and that unpaid deposits remain payable from CRBBI’s assets.
- On Dec