Servo v. Philippine Deposit Insurance Corporation
REITERATIONFacts
1. The Antecedents: Petitioner Connie L. Servo filed a claim for deposit insurance with the Philippine Deposit Insurance Corporation (PDIC) after the Rural Bank of San Jose Del Monte, where she had a time deposit account, was closed. Servo alleged that she lent P500,000.00 to Teresita Guiterrez, and for the purpose of receiving Guiterrez's loan payment, she opened a time deposit account using Guiterrez's name as the account holder, as Guiterrez was a preferred client. Servo claimed to be the exclusive owner of the account, held in trust by Guiterrez. PDIC denied the claim, citing the absence of bank records showing Servo as the owner and the lack of documents proving a valid consideration for the transfer of the deposit, noting Servo was not a relative of Guiterrez. 2. Procedural History: Following PDIC's denial of her claim and subsequent request for reconsideration, petitioner Servo filed an action for certiorari with the Regional Trial Court (RTC), alleging grave abuse of discretion by PDIC. The RTC dismissed the case for lack of jurisdiction, ruling that PDIC, as a quasi-judicial agency, falls under the appellate jurisdiction of the Court of Appeals (CA) as per Section 5(g) of Republic Act No. 3591, as amended. Servo then filed a special civil action for certiorari with the CA, arguing that PDIC was not among the quasi-judicial bodies enumerated in Rule 43 of the Rules of Court and that the CA had original jurisdiction over such writs. The CA dismissed this petition, however, stating that the case involved a pure legal question and should have been filed with the Supreme Court under Rule 45. 3. The Petition: Petitioner Servo seeks review of the CA's resolution dismissing her petition for certiorari. She argues that the CA erred in ruling that it lacked jurisdiction, as Section 9 of Batas Pambansa Bilang 129 grants the CA original jurisdiction over petitions for certiorari, irrespective of whether the issues are factual or legal. Servo contends that the CA should have exercised its jurisdiction and resolved the merits of her claim, or at least treated her petition as an original action. The Supreme Court, however, notes that while the CA erred in dismissing the case on jurisdictional grounds, the PDIC's actions are now exclusively assailable before the CA via a petition for certiorari under Rule 65, within thirty days of denial, as per Section 5(g) of RA 3591, as amended by RA 10846. Since Servo filed her petition with the CA more than two years after the denial of her claim, it was filed beyond the reglementary period, rendering it moot.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari on the ground of lack of jurisdiction. Whether the PDIC's actions concerning insured deposits and deposit liabilities are exclusively assailable before the Court of Appeals via a petition for certiorari under RA 10846, overriding the general rule on concurrent jurisdiction.
Ruling
The petition is DENIED. The Supreme Court found that the Court of Appeals erred in dismissing the petition for certiorari on the ground that the case involved a pure question of law, as Section 9 of BP 129 grants concurrent jurisdiction to the RTC, CA, and SC over special civil actions and auxiliary writs. However, the Court resolved the jurisdictional issue itself, holding that under Section 5(g) of RA 3591, as amended by RA 10846, actions of the PDIC are exclusively assailable before the Court of Appeals via a petition for certiorari within thirty (30) days from notice of denial of claim. Since the petition was filed beyond the reglementary period, the Court of Appeals could not have granted the prayer to treat it as a petition filed in accordance with PDIC rules.
Ratio Decidendi
On the Court of Appeals' dismissal for lack of jurisdiction: The Court held that the Court of Appeals erred in dismissing the petition for certiorari solely on the ground that it involved a pure question of law. Section 9 of Batas Pambansa Bilang 129 (BP 129) grants concurrent jurisdiction to the Regional Trial Courts, the Court of Appeals, and the Supreme Court over special civil actions and auxiliary writs. The law does not distinguish the nature of the issues (factual or legal) for determining which court should take cognizance of such cases. The Court reiterated the policy on the hierarchy of courts, emphasizing that direct resort to the Supreme Court for extraordinary writs should be allowed only when there are special and important reasons. The Court of Appeals' dismissal based on the nature of the issue was therefore incorrect. On the exclusive jurisdiction over PDIC actions: The Court clarified that, notwithstanding the concurrent jurisdiction over certiorari petitions, the specific provisions of RA 10846, amending the PDIC Charter, dictate the proper venue for assailing PDIC's actions. Section 5(g) of RA 3591, as amended by RA 10846, explicitly states that actions of the PDIC concerning insured deposits and deposit liabilities are final and executory and may only be restrained or set aside by the Court of Appeals upon an appropriate petition for certiorari. This petition must be filed within thirty (30) days from notice of denial of the claim for deposit insurance. This provision clearly vests exclusive original jurisdiction in the Court of Appeals for such matters, overriding the general rule on concurrent jurisdiction for certiorari petitions.
Main Doctrine
The Court of Appeals erred in dismissing a petition for certiorari on the ground that the case involved a pure question of law, as Section 9 of BP 129 vests concurrent jurisdiction in the RTC, CA, and SC over special civil actions and auxiliary writs, irrespective of the nature of the issues involved. However, the Supreme Court, in the interest of justice and to avoid further delay, resolved the jurisdictional issue itself, holding that under Section 5(g) of RA 3591, as amended by RA 10846, actions of the PDIC are exclusively assailable before the Court of Appeals via a petition for certiorari within thirty (30) days from notice of denial of claim.