Bangko Sentral v. Campa
REITERATIONFacts
The Antecedents: Bankwise applied for a Special Liquidity Facility (SLF) loan from Bangko Sentral ng Pilipinas (BSP) in 2000. BSP required Bankwise to submit mortgages of properties owned by third parties to secure the obligation. Bankwise complied by mortgaging properties owned by Eduardo Aliño, Haru Gen Beach Resort and Hotel Corporation, and respondents Vicente Jose Campa, Jr., et al. When Bankwise failed to pay, BSP initiated extra-judicial foreclosure proceedings, and the properties were sold at public auction to BSP. Procedural History: Eduardo Aliño filed a Complaint for specific performance, novation of contracts, and damages with application for TRO/preliminary injunction against BSP and Bankwise, alleging that BSP foreclosed his properties despite assurances of a dacion en pago settlement and the availability of properties offered for dacion sufficient to cover the obligation. Haru Gen Beach Resort and Hotel Corporation filed a Motion for Leave to Admit Complaint in Intervention, claiming their mortgage was void for lack of consideration and proper authorization, but this was denied by the RTC. Subsequently, respondents Vicente Jose Campa, Jr., et al. filed a similar Motion for Leave to Intervene and Admit Complaint-in-Intervention, repleading Aliño's causes of action. BSP opposed this motion, arguing that the requirements for intervention were not met, the complaint lacked cause of action, and the intervention was a scheme to delay consolidation of title. The RTC granted the intervention. BSP appealed via certiorari to the Court of Appeals (CA), alleging grave abuse of discretion. The CA affirmed the RTC's decision, finding no grave abuse of discretion. BSP filed a motion for reconsideration, which was denied. The Petition: BSP filed a petition for review with the Supreme Court, assailing the CA's resolution. BSP argued that private respondents failed to satisfy the requisites for intervention and that they should not be treated differently from Haru Gen, whose intervention was denied. BSP contended that the original complaint was a derivative suit, and respondents, not being stockholders of VR Holdings, lacked legal interest. The Supreme Court, however, found that the complaint was not a derivative suit.
Issue(s)
Whether the respondents satisfied the requisites for intervention. Whether the respondents should be treated differently from Haru Gen, whose intervention was denied. Whether the complaint filed by Eduardo Aliño constitutes a derivative suit; and whether the Regional Trial Court (RTC) has jurisdiction over the complaint if it is not a derivative suit. Whether the intervention, being ancillary to the main action, is proper.
Ruling
The petition is partly granted. The Decision and Resolution of the Court of Appeals are set aside. The Complaint in Commercial Case No. 06-114866 is referred to the Executive Judge of the Regional Trial Court of Manila for re-docketing as a civil case, and thereafter, to be raffled to all branches of the RTC of Manila. The assigned Branch is ordered to resolve the case with reasonable dispatch. The Clerk of Court of RTC Manila shall determine the appropriate docket fees and order payment or refund any excess.
Ratio Decidendi
On the propriety of intervention: The Court held that intervention is merely ancillary and supplemental to the main action. A court that has no jurisdiction over the principal action has no jurisdiction over a complaint-in-intervention. Since the RTC had already acquired jurisdiction upon the filing of the complaint, and the issue of jurisdiction was resolved by ordering a re-raffling of the case, the intervention, being ancillary, would proceed in the court where the principal action is assigned after the re-raffling. The Court did not delve into the merits of whether the respondents met the requisites for intervention, as the primary issue revolved around the jurisdiction and proper venue of the main case. There was no specific ratio provided regarding why the respondents should be treated differently from Haru Gen, whose intervention was denied. Therefore, this issue remains unaddressed in the provided text. On the nature of the complaint and jurisdiction: The Court found that the complaint filed by Eduardo Aliño was not a derivative suit. A derivative suit is filed by a stockholder on behalf of the corporation to protect corporate rights when corporate officials refuse to sue or are the ones being sued. The allegations in Aliño's complaint pertained to the injury caused to him and other third-party mortgagors concerning their personal properties, not to the corporation. The prayer for relief also sought the recovery of personal properties belonging to third-party mortgagors. Therefore, the damage did not devolve on the corporation, and the suit was not for the benefit of the corporation. The Court noted that the original complaint was filed in a special commercial court, but since it was not a derivative suit, it was an ordinary civil case. Citing Gonzales v. GJH Land, the Court held that the designation of Special Commercial Courts is a procedural tool and does not divest RTCs of their general jurisdiction. Thus, dismissal for lack of jurisdiction was no longer the proper recourse; instead, the case should be re-raffled to all RTC branches of the same station. Following the ruling in Gonzales v. GJH Land, the Court ordered the re-docketing of the case as a civil case and its subsequent raffling to all branches of the Regional Trial Court of Manila. This was to ensure that the case would be heard by a court with competent jurisdiction, given that the initial designation as a special commercial court was merely procedural. The Court emphasized that the designation of Special Commercial Courts, being an internal rule, cannot override the general jurisdiction of the RTCs as established by Batas Pambansa Bilang 129. The Executive Judge was directed to determine the appropriate docket fees and order payment or refund any excess. On the propriety of intervention: The Court held that intervention is merely ancillary and supplemental to the main action. A court that has no jurisdiction over the principal action has no jurisdiction over a complaint-in-intervention.
Main Doctrine
A case that is not a derivative suit, even if initially filed in a special commercial court, should be re-raffled to all RTC branches of the same station, as the designation of special commercial courts is a procedural tool and does not divest RTCs of their general jurisdiction. Dismissal for lack of jurisdiction is no longer the proper recourse.