unissued CTD's in the inventory submitted by RBMI to PDIC;
and
Full Case Title: Spouses Kishore Ladho Chugani and Prisha Kishore Chugani
et al., vs. Philippine Deposit Insurance Corporation (PDIC) c. The amounts purportedly deposited by the petitioners were
credited to the personal account of Garan, hence, they could
Doctrine: Appealing a decision of a quasi judicial agency in the exercise of its not be construed as valid liabilities of RBMI.
quasi-judicial functions, the appropriate remedy is a petition for certiorari 4. Petitioners filed MR for the denial of claim. This was rejected.
with the Court of Appeals. 5. Petitioners filed a petition for certiorari under Rule 65 with the RTC.
RTC Decision: RTC issued a consolidated order dismissing the petition for lack
Recit - Ready Summary: PDIC refuses to pay out to Sps that had time
of jurisdiction.
deposits with a bank that was held in receivership. Sps file petition for
certiorari directly with RTC. The Court ruled this as wrong, showing the
relevant provision of law that required the Sps to file such Rule 65 petition CA Decision: Denied the petitioners’ appeal. MR also denied.
with the CA.
Issue/s: Whether or not the RTC has jurisdiction over the petitions for
Facts: certiorari filed by the petitioners. (No)
1. Petitioners, upon invitation of a Raymundo Garan (president of the
Rural Bank of Mawab or RBMI), signified their intention to open time For purposes of discussion on certiorari: Was petition for certiorari the
deposits with RBMI. proper remedy? (Yes, under rule 65. But not to the RTC, but rather the CA.)
a. RBMI sent to petitioners, through courier, time deposit
signature cards and personal information sheets. Ratio/ Legal Basis:
b. Petitioners opened time deposit accounts with RBI through On the question of jurisdiction:
interbranch deposits to RBMI accounts in Metrobank and First, the court delved into the nature of the PDIC as an insurer of deposits in
Chinabank all banks to safeguard the interests of the depositing public.
c. Certificates of time deposits and official receipts were issued - Based on its charter, the PDIC has the duty to grant or deny claims for
to petitioners. deposit insurance.
2. 2011, petitioners found out that the Monetary Board of the BSP had
placed RBMI under receivership and had closed RBMI. Then, the court explained that the PDIC has the power to prepare and issue
a. Petitioners filed claims for insurance of their time deposits. rules and regulations to discharge its responsibilities. Their power to deny or
3. Respondent PDIC refused to pay the claims, citing the ff. grounds: grant claims for deposit insurance takes after the nature of a quasi-judicial
a. Based on bank records submitted by RBMI, petitioners' function.
deposit accounts are not part of RBMI's outstanding deposit - The fact that decisions of the PDIC regarding deposit insurance are
liabilities; final and executory and only susceptible to being set aside by petition
b. The time deposits of petitioners are fraudulent and their CTDs for certiorari reveals the legislative intent to make PD a quasi-judicial
were not duly issued by RBMI, but were mere replicas of agency.
As such, S4R65 states that the CA has the jurisdiction to rule on the alleged
grave abuse of discretion, and not the RTC.
- The CA was therefore correct in holding that the RTC had no
jurisdiction over the petitioners’ claims.
The pertinent law here is RA 10846, S7 that provides:
- That actions of corporations… and may only be restrained or set aside
by the CA upon appropriate petition for certiorari on the grounds of
grave abuse of discretion amounting to lack or excess of jurisdiction.
The
Disposition: WHEREFORE, the petition is DENIED. The Decision dated June 29,
2016 of the Court of Appeals in CA-G.R. SP No. 141770 is hereby AFFIRMED.
SO ORDERED.
Laws Cited:
Section 4(f) of R.A. No. 3591, as amended by R.A. No. 9576, provides that:
"The actions of the Corporation taken under this section shall be final and
executory, and may not be restrained or set aside by the court, except on
appropriate petition for certiorari on the ground that the action was taken in
excess of jurisdiction or with such grave abuse of discretion as to amount to a
lack or excess of jurisdiction. The petition for certiorari may only be filed
within thirty (30) days from notice of denial of claim for deposit insurance."
Section 4, Rule 65 of the Rules of Court: The CA has the jurisdiction to rule on
the alleged grave abuse of discretion of the PDIC.
Cases Cited:
