Bangko Sentral ng Pilipinas v. Banco Filipino Savings
REITERATIONFacts
The Antecedents: Banco Filipino Savings and Mortgage Bank (BFSMB) commenced operations in 1964 but was placed under conservatorship in 1984 and subsequently ordered closed by the Central Bank Monetary Board (CB-MB) in 1985 due to insolvency. BFSMB challenged this closure, and in 1991, the Supreme Court annulled the closure order, directing the CB-MB to reorganize BFSMB and allow it to resume business under its comptrollership. Procedural History: Following the Supreme Court's 1991 decision, BFSMB reopened in 1994 under the comptrollership of the Bangko Sentral ng Pilipinas (BSP), which replaced the CB. A Memorandum of Agreement in 1999 stipulated BFSMB's repayment of advances through property transfer. In 2002, BFSMB faced liquidity issues, and its subsequent requests for financial assistance from the BSP were denied. In 2004, BFSMB filed a Petition for Revival of Judgment to enforce the 1991 Supreme Court decision. The Regional Trial Court (RTC) denied the motions to dismiss filed by the BSP and the Central Bank-Board of Liquidators (CB-BOL). The Court of Appeals (CA) issued conflicting decisions: one affirming the RTC's denial of dismissal (CA-G.R. SP No. 96831), and another reversing it and dismissing the petition for revival (CA-G.R. SP No. 96280). The Petition: Two consolidated petitions for review on certiorari under Rule 45 were filed. G.R. No. 178696, filed by the BSP-MB, assails the CA decision that upheld the RTC's denial of dismissal. G.R. No. 192607, filed by BFSMB, seeks to reverse the CA decision that dismissed the petition for revival. The core of the dispute revolves around whether the petition for revival of judgment was filed within the prescriptive period, whether the judgment obligation had been extinguished, and whether the reliefs sought by BFSMB were within the scope of the original Supreme Court decision. The BSP-MB argues that the petition was time-barred and the obligations were already fulfilled, while BFSMB contends that the BSP is obligated to fully reorganize it and provide financial assistance as per the 1991 ruling.
Issue(s)
Whether the action for revival of judgment filed by Banco Filipino Savings and Mortgage Bank (BFSMB) in 2004 had already prescribed. Whether the enactment of Republic Act No. 7653 (RA 7653) tolled the prescriptive period for the revival of the 1991 judgment. Whether the reliefs prayed for by BFSMB (financial assistance and business plan approval) are within the scope of the 1991 judgment sought to be revived.
Ruling
The petition in G.R. No. 178696 (BSP-MB's petition) is meritorious, while the petition in G.R. No. 192607 (BFSMB's petition) lacks merit. The Supreme Court REVERSED and SET ASIDE the decision of the Court of Appeals in CA-G.R. SP No. 96831 and AFFIRMED the decision of the Court of Appeals in CA-G.R. SP No. 96280. Consequently, the Petition for Revival of Judgment filed by BFSMB is DISMISSED for lack of merit.
Ratio Decidendi
On Issue 1: The Court ruled that the action had clearly prescribed. Under Rule 39, Section 6 of the Rules of Court and Article 1144 of the Civil Code, a judgment may be executed by motion within five years from entry, and thereafter by an independent action for revival within ten years from the time the judgment becomes final. Since the judgment in G.R. No. 70054 became final on February 4, 1992, BFSMB had only until February 4, 2002, to file an action for revival. The petition filed on July 14, 2004, was more than two years late. On Issue 2: The Court rejected the argument that RA 7653 tolled the prescriptive period. There was no 'legal vacuum' created by the abolition of the Central Bank of the Philippines (CB) because RA 7653 explicitly identified the Bangko Sentral ng Pilipinas (BSP) as the transferee of powers and duties, and the Central Bank-Board of Liquidators (CB-BOL) as the entity responsible for liabilities not transferred to the BSP. Therefore, the entities against whom BFSMB could enforce the judgment were always identifiable. Furthermore, Article 1155 of the Civil Code regarding the tolling of prescription applies to actions to collect debts under contracts or law, not to the enforcement of a court judgment. On Issue 3: The Court held that the judgment obligation had already been extinguished by performance and could not be expanded. The 1991 Decision only mandated that BFSMB be 'reorganized' and 'reopened' under conditions prescribed by the Monetary Board (MB). BFSMB admitted that it reopened in 1994 and signed a Memorandum of Agreement in 1999 acknowledging that the BSP had complied with the Supreme Court's decision. An action for revival cannot modify a final judgment to include specific financial aid or the restoration of a specific number of branches when those were not in the original dispositive portion. Such matters are discretionary regulatory functions of the BSP-MB that cannot be mandated by judicial compulsion through a revival action.
Main Doctrine
A petition for revival of judgment must be filed within ten (10) years from the date the judgment became final and executory. The passage of Republic Act No. 7653 did not toll the prescriptive period as the entities responsible for the judgment's enforcement remained identifiable. Furthermore, the obligation imposed by the judgment was deemed extinguished by performance, as evidenced by the reopening and reorganization of the bank under comptrollership, and the subsequent Memorandum of Agreement.