Rosario v. Philippine Deposit Insurance Corporation
REITERATIONFacts
The Antecedents: Petitioners, depositors of the Rural Bank of Alcala, Pangasinan, Inc. (Bank), filed a complaint for sum of money with damages against the Philippine Deposit Insurance Corporation (PDIC) and the Bank's officers and stockholders. They alleged that through misrepresentations and enticements of high interest rates, they opened time deposit accounts with the Bank, depositing an aggregate amount of P2,241,821.75. After initially earning interest, they were unable to withdraw their deposits because the Bank suffered a bank run from December 1991 to March 1992 and was subsequently ordered closed by the Monetary Board. PDIC took over the Bank and initiated liquidation proceedings. Petitioners claimed PDIC was only willing to pay 25% of their deposits. They further alleged that the bank run was caused by the Bank's officers and stockholders granting loans to bank officers and fictitious persons who failed to comply with their obligations. Procedural History: Petitioners filed their complaint with the Regional Trial Court (RTC) of San Carlos City, Pangasinan. Respondents officers and stockholders filed motions to dismiss, arguing that the complaint stated no cause of action against them as their liability should be solely against the Bank, which has a separate juridical personality. PDIC denied negotiating with petitioners and asserted it acted in accordance with Republic Act No. 3591. Petitioners amended their complaint to implead the Bank, which, through PDIC as receiver, filed a motion to dismiss, asserting lack of jurisdiction due to improper summons service and the exclusive jurisdiction of the RTC of Villasis, Pangasinan, where the liquidation proceedings were pending. The San Carlos RTC dismissed the case for lack of jurisdiction. The Court of Appeals affirmed the dismissal, holding that the court handling the liquidation proceedings acquires exclusive jurisdiction over all claims against the bank, its stockholders, directors, and officers, and that petitioners' claims against the officers were dependent on their claims against the Bank. The Petition: Petitioners filed a petition for review on certiorari with the Supreme Court, arguing that the San Carlos RTC should not have dismissed their complaint based solely on allegations of pending liquidation proceedings without evidence, and that their claims against the individual respondents were separate from those against the Bank. They also argued that their motion for reconsideration with the Court of Appeals was filed on time, based on their counsel's actual receipt of the decision.
Issue(s)
Whether or not the Motion for Reconsideration filed by petitioners with the Court of Appeals on 04 November 1999 was filed on time. Whether or not the Court of Appeals was correct in affirming the dismissal by the RTC of San Carlos City, Pangasinan, Branch 57, of petitioners’ complaint for lack of jurisdiction in view of the pendency of the liquidation proceedings involving the Bank in the RTC of Villasis, Pangasinan, Branch 50.
Ruling
The petition is denied. The Supreme Court held that the petition should have been denied outright for non-compliance with the requirements under Rule 45 of the 1997 Rules of Civil Procedure. Furthermore, even if the petition complied with the requirements, it must be dismissed due to the late filing of the Motion for Reconsideration with the Court of Appeals, which had already rendered the assailed decision final and executory.
Ratio Decidendi
On the timeliness of the Motion for Reconsideration: The Court found that the Court of Appeals correctly determined that the Motion for Reconsideration was filed out of time. The appellate court relied on the Postmaster's report indicating delivery of the decision on 12 October 1998. Under the rules, the fifteen-day period to file a motion for reconsideration should be reckoned from this date, making the deadline 27 October 1998. Petitioners erroneously computed the period from 26 October 1998, the date their counsel allegedly actually saw the copy. Consequently, the motion filed on 04 November 1999 was beyond the reglementary period, rendering the Court of Appeals' decision final and executory. On the jurisdiction of the RTC and the Court of Appeals' affirmation of dismissal: The Court reiterated that the court where liquidation proceedings are pending acquires exclusive jurisdiction over all claims against the bank. Section 30 of Republic Act No. 7653 (The New Central Bank Act) explicitly grants this exclusive jurisdiction not only over claims against the bank but also over claims against its stockholders, directors, and officers, as the liquidation court is mandated to "assist in the enforcement of individual liabilities of the stockholders, directors and officers." Therefore, the San Carlos RTC correctly dismissed the case for lack of jurisdiction, as the RTC of Villasis, Pangasinan, where the liquidation proceedings were ongoing, had exclusive cognizance of the matter. The claims against the officers and stockholders were intrinsically linked to the claims against the Bank and thus fell within the exclusive jurisdiction of the liquidation court.
Main Doctrine
The court where liquidation proceedings are pending acquires exclusive jurisdiction over all claims against the bank, including claims against its stockholders, directors, and officers, as it is mandated to assist in the enforcement of individual liabilities. A motion for reconsideration filed beyond the reglementary period, as determined by the date of receipt of the decision, is considered filed out of time and renders the decision final and executory.