So v. Philippine Deposit Insurance Corporation
REITERATIONFacts
1. The Antecedents: Peter L. So opened a Special Incentive Savings Account (SISA) with Cooperative Rural Bank Bulacan (CRBB) amounting to P300,000. Subsequently, CRBB was placed under the receivership of the Philippine Deposit Insurance Corporation (PDIC). So filed an insurance claim with PDIC, which was denied. PDIC determined that So's account originated from and was funded by the proceeds of a terminated SISA jointly owned by the Reyes family, constituting a prohibited splitting of a deposit. 2. Procedural History: Following the denial of his insurance claim and a subsequent request for reconsideration by the PDIC, Peter L. So filed a Petition for Certiorari under Rule 65 with the Regional Trial Court (RTC) of Makati, Branch 138. The RTC dismissed the petition for lack of jurisdiction, holding that PDIC exercises quasi-judicial functions and that such petitions should be filed with the Court of Appeals (CA). The RTC also cited provisions of PDIC's Charter (RA 3591) which limit the jurisdiction for injunctions against PDIC to the CA. 3. The Petition: This case is a Petition for Review on Certiorari under Rule 45 of the Rules of Court, filed by Peter L. So. He assails the RTC's decision dismissing his Petition for Certiorari for lack of jurisdiction. So argues that the RTC has jurisdiction over his Rule 65 petition because PDIC is not a quasi-judicial agency and that the RTC, CA, and Supreme Court have concurrent original jurisdiction over such petitions based on the Judiciary Reorganization Act and the Rules of Court. The core issue is whether the RTC has jurisdiction over a petition for certiorari assailing the PDIC's denial of a deposit insurance claim.
Issue(s)
Whether the Regional Trial Court (RTC) has jurisdiction over a petition for certiorari filed under Rule 65, assailing the Philippine Deposit Insurance Corporation's (PDIC) denial of a deposit insurance claim. Whether the PDIC exercises quasi-judicial functions when determining the validity of deposit insurance claims.
Ruling
The Supreme Court denied the petition for lack of merit. It affirmed the RTC's dismissal of the petition for lack of jurisdiction, holding that the Court of Appeals, not the RTC, has jurisdiction over petitions for certiorari assailing the PDIC's denial of deposit insurance claims.
Ratio Decidendi
On the jurisdiction of the RTC over a petition for certiorari assailing PDIC's denial of a deposit insurance claim: The Court held that the RTC erred in taking cognizance of the petition for certiorari. Section 4(f) of PDIC's Charter, as amended, clearly states that actions of the PDIC taken under that section are final and executory and may only be set aside by an appropriate petition for certiorari on the ground of excess of jurisdiction or grave abuse of discretion. Crucially, the Court clarified that such a petition must be filed with and cognizable only by the Court of Appeals, unless otherwise provided by law or rules. This is further supported by Section 22 of RA 3591, as amended, which explicitly states that no court, except the Court of Appeals, shall issue any temporary restraining order, preliminary injunction, or preliminary mandatory injunction against the PDIC for any action under the Act. The recent amendment under RA 10846 also confirms this exclusive jurisdiction of the CA. On whether PDIC exercises quasi-judicial functions: The Court affirmed that PDIC exercises quasi-judicial functions when determining the validity of deposit insurance claims. The Court explained that quasi-judicial power involves the adjudication of rights of persons before it, requiring the agency to investigate facts, hold hearings, weigh evidence, and draw conclusions as a basis for its official action and exercise of discretion in a judicial nature. PDIC's mandate to determine the validity of claims, its actions being considered final and executory, and the review limited to grave abuse of discretion all point to the exercise of such powers. The Court cited Lintang Bedol v. Commission on Elections and Carlito C. Encinas v. PO1 Alfredo P. Agustin, Jr. and PO1 Joel S. Caubang to define quasi-judicial power, emphasizing that adjudication signifies the exercise of power and authority to adjudicate upon the rights and obligations of parties. PDIC's determination of a claimant's entitlement to deposit insurance, based on investigation and weighing of evidence, falls squarely within this definition, thus confirming its quasi-judicial nature in this context.
Main Doctrine
A petition for certiorari assailing the denial of a deposit insurance claim by the Philippine Deposit Insurance Corporation (PDIC) must be filed with the Court of Appeals, not the Regional Trial Court, as the PDIC exercises quasi-judicial functions in such matters.