Case Summary (G.R. No. 234401)
PDIC’s Denials
On August 27, 2014, PDIC denied the claim for lack of bank records proving Servo’s ownership. After Servo’s RFR on October 30, 2014, PDIC reiterated its denial on July 16, 2015, citing absence of valid consideration for the transfer and noting that Servo was not a close relative of Guiterrez.
Trial Court Proceedings and Dismissal
Servo filed a petition for certiorari with the RTC on August 19, 2016, alleging grave abuse of discretion by PDIC. On July 27, 2017, the RTC dismissed the petition for lack of jurisdiction, holding that PDIC’s quasi-judicial actions are reviewable only by the Court of Appeals under Section 5(g) of RA 3591, as amended.
Court of Appeals Proceedings
In CA-G.R. SP No. 152398, Servo contended PDIC is not among the agencies listed in Rule 43, Section 1, and that its decisions are not automatically appealable to the CA. The CA, however, on September 22, 2017, dismissed her petition for certiorari for lack of jurisdiction, ruling that pure questions of law fall under the Supreme Court’s Rule 45 original jurisdiction.
Issue on Jurisdiction
The central issue is whether the CA erred in dismissing Servo’s certiorari petition for lack of jurisdiction when PDIC’s denials may only be challenged by certiorari before the CA under RA 3591, as amended by RA 10846.
Supreme Court’s Ruling on CA Error
The Supreme Court held that BP 129 §9 grants concurrent original jurisdiction to the RTC, CA, and Supreme Court over certiorari petitions, irrespective of whether issues are purely legal or factual. The CA improperly invoked exclusivity of the Supreme Court’s jurisdiction under Rule 45.
PDIC Charter Provisions and Jurisdictional Clarity
Under RA 3591 §5(g), as amended by RA 10846, PDIC’s final and executory actions on deposit insurance may only be set aside by the CA via a Rule 65 certiorari petition within 30 days of denial. Section 22 of the Charter likewise bars lower c
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Antecedents
- On August 22, 2014, petitioner Connie L. Servo filed a claim for deposit insurance with the Philippine Deposit Insurance Corporation (PDIC).
- She alleged that in October 2011 she lent P500,000.00 to Teresita Gutierrez for bus repairs.
- On January 19, 2012, the parties opened Special Savings Deposit (SSD) Account No. 001-03-00904-1 in Gutierrez’s name at the Rural Bank of San Jose Del Monte, but the funds were held in trust for petitioner.
- The Rural Bank later closed, prompting petitioner’s claim with PDIC, wherein she asserted exclusive ownership of the SSD account and trust arrangement.
Proceedings Before PDIC
- By letter dated August 27, 2014, PDIC denied petitioner’s claim for lack of bank records showing her as owner of the account.
- Petitioner filed a Request for Reconsideration on October 30, 2014.
- On July 16, 2015, PDIC again denied the claim, stating petitioner failed to prove that the transfer of the deposit was for valid consideration and noting petitioner was not within the second degree of consanguinity or affinity of Gutierrez.
Trial Court Ruling
- Petitioner filed a special civil action for certiorari in the Regional Trial Court (RTC), alleging grave abuse of discretion by PDIC for denying her claim without allowing submission of additional documents or a clarificatory meeting as required under Regulatory Issuance No. 2011-03, Sections 4(b) and 4(c).
- PDIC moved to dismiss for lack of jurisdiction, asserting its quasi-judicial decisions could only be reviewed by the Court of Appeals.
- By Decision dated July 27, 2017, the RTC dismissed the case for lack of jurisdiction, citing Section 5(g) of PDIC’s Charter (RA 3591, as amended by RA 10846), which vests exclusive review of PDIC actions in the Court of Appeals.
Proceedings Before the Court of Appeals
- Petitioner filed a special civil action for certiorari with the Court of Appeals, arguing PDIC is not among the quasi-judicial bodies under Rule 43, Section 1 of the Rules of Court, and that PDIC decisions are not appealable solely to that Court.
- She a