Fil-Agro Rural Bank v. Villasenor
REITERATIONFacts
The Antecedents: Antonio J. Villaseñor, Jr. filed a complaint seeking to nullify real estate mortgages executed by his wife, Wilfreda V. Villaseñor, in favor of Fil-Agro Rural Bank, Inc. (Fil-Agro). Antonio alleged that these mortgages, covering conjugal properties, were made without his knowledge and consent while he was abroad. Subsequently, Fil-Agro was placed under the receivership of the Philippine Deposit Insurance Corporation (PDIC) by the Bangko Sentral ng Pilipinas. Procedural History: The Regional Trial Court (RTC) of Pasig City initially handled the case. Despite Fil-Agro's counsel withdrawing and requesting notices be sent to the PDIC, the RTC proceeded with pre-trial. Fil-Agro and Wilfreda failed to appear, leading the RTC to declare them in default and allow Antonio to present evidence ex parte. Fil-Agro's subsequent motion for reconsideration was denied, and the RTC admitted Antonio's evidence. Fil-Agro then filed a Petition for Certiorari with the Court of Appeals (CA), which ordered the consolidation of the case with the liquidation proceedings but upheld the RTC's orders regarding default and the denial of the motion for reconsideration. The Petition: Both Antonio and Fil-Agro filed Petitions for Review on Certiorari with the Supreme Court. Antonio argued against the consolidation, asserting his claim was not a disputed claim within the liquidation court's jurisdiction. Fil-Agro contended that the CA's ruling on consolidation rendered the RTC's earlier orders void. The Supreme Court granted Fil-Agro's petition, modifying the CA's decision to declare the RTC's Orders dated June 29, 2015, and September 28, 2015, as null and void for lack of jurisdiction, affirming the CA's order for consolidation.
Issue(s)
Whether or not consolidation of the instant civil case for annulment of real estate mortgage, quieting of title, and damages with the liquidation case is proper, and whether the liquidation court has exclusive jurisdiction over claims against the bank. Whether or not the June 29, 2015 and September 28, 2015 Orders of the RTC are valid, considering the liquidation proceedings.
Ruling
The Supreme Court granted the petition in G.R. No. 226761 (Fil-Agro) and denied the petition in G.R. No. 226889 (Antonio). The Court affirmed the CA's Decision and Resolution with modification, declaring the RTC Orders dated June 29, 2015, and September 28, 2015, null and void for lack of jurisdiction.
Ratio Decidendi
On the propriety of consolidation and jurisdiction: The Court held that when a bank is placed under receivership and liquidation, the liquidation court, in this case, the RTC of Malolos City, acquires exclusive jurisdiction over all claims against the bank. Section 30 of R.A. No. 7653 clearly states that the liquidation court shall adjudicate disputed claims against the institution. The claim filed by Antonio, which assails Fil-Agro's right to foreclose the mortgages, is a disputed claim falling within the exclusive jurisdiction of the liquidation court. Therefore, the consolidation of the case with the liquidation proceedings was proper to avoid multiplicity of suits and ensure orderly adjudication of claims against the closed bank. The CA correctly ordered the consolidation. On the validity of the RTC Orders: The Court ruled that the RTC of Pasig City, a court of general jurisdiction, had no jurisdiction over Antonio's complaint once Fil-Agro was placed under liquidation. The exclusive jurisdiction vested in the liquidation court renders any order, judgment, or resolution issued by a regular trial court concerning claims against the closed bank null and void. Consequently, the RTC's Orders dated June 29, 2015 (declaring Fil-Agro and Wilfreda in default and allowing ex parte presentation of evidence) and September 28, 2015 (denying the motion for reconsideration) are void for having been issued without jurisdiction. The RTC should have deferred to the liquidation court's authority over the matter.
Main Doctrine
All claims against a bank under liquidation, regardless of their nature, must be filed with the liquidation court, which has exclusive jurisdiction to adjudicate them. Orders issued by a regular trial court in violation of this exclusive jurisdiction are void.