Hermosa Savings and Loan Bank v. Development Bank of the Philippines
REITERATIONFacts
The Antecedents: The Development Bank of the Philippines (DBP) extended subsidiary loans to Hermosa Savings and Loan Bank, Inc. (Hermosa Bank) for relending to sub-borrowers. Hermosa Bank, through its President and General Manager Benjamin Cruz, executed loan agreements and submitted supporting documents. DBP approved and released the loan proceeds. Subsequently, Hermosa Bank failed to remit loan amortizations, leading DBP to declare its subsidiary loan in default. Investigations by the Bangko Sentral ng Pilipinas (BSP) and DBP revealed suspicions of tampering and falsification of loan documents and collateral, indicating fraudulent acts by Hermosa Bank and its officers to defraud DBP. As of June 30, 2001, Hermosa Bank's aggregate availment of the IGLF loan facility amounted to P438,235,392.60. Procedural History: On September 25, 2001, DBP filed a complaint for sum of money and damages against Hermosa Bank and its officers before the Regional Trial Court (RTC) of Makati City, Branch 136. A Writ of Preliminary Attachment was issued and later lifted, then reinstated. On February 5, 2005, the BSP placed Hermosa Bank under receivership with the Philippine Deposit Insurance Corporation (PDIC) as receiver. PDIC filed a petition for assistance in the liquidation of Hermosa Bank. Hermosa Bank and its officers moved to dismiss DBP's complaint, arguing that the case should be filed before the Liquidation Court. RTC Branch 136 initially dismissed the complaint, reinstated it, and then dismissed it again for lack of jurisdiction, ruling that the Liquidation Court had exclusive jurisdiction. The case was re-raffled to RTC Branch 57, which also denied DBP's motion for reconsideration, upholding the dismissal. DBP appealed to the Court of Appeals (CA). The Petition: The Court of Appeals reversed the RTC's dismissal orders, reinstating DBP's complaint and the Writ of Preliminary Attachment, and ordering the RTC to proceed with the case. The CA ruled that the RTC retained jurisdiction as the case was filed before Hermosa Bank was placed under receivership and that the complaint also involved claims against bank officers in their personal capacities. Hermosa Bank and its officers filed a motion for reconsideration, which the CA denied. This led to the filing of the present Petition for Review on Certiorari under Rule 45 of the Rules of Court by Hermosa Savings and Loan Bank, Inc., represented by its Statutory Liquidator, the Philippine Deposit Insurance Corporation (PDIC), assailing the CA's decision and resolution. The core issue is whether the RTC retained jurisdiction over the complaint despite the pendency of the liquidation proceedings.
Issue(s)
Whether the Regional Trial Court (RTC) retained jurisdiction over DBP's complaint despite Hermosa Bank being placed under liquidation. Whether the Court of Appeals erred in reinstating the writ of preliminary attachment.
Ruling
The Supreme Court granted the petition, reversed and set aside the Decision and Resolution of the Court of Appeals, and reinstated the Orders of the RTC dismissing DBP's complaint. It directed DBP to file its claim before the liquidation court.
Ratio Decidendi
On the issue of jurisdiction: The Court ruled that the CA erred in holding that the RTC retained jurisdiction. While jurisdiction is generally not lost once acquired, Section 30 of Republic Act No. 7653 is curative in character, granting the liquidation court exclusive jurisdiction over all claims against a bank under liquidation. This is to prevent multiplicity of actions against the insolvent bank, establish due process and orderliness, and avoid injustice and arbitrariness. The Court clarified that the timing of the filing of the complaint is immaterial, as the execution of any judgment would prejudice other depositors and creditors. Allowing DBP's claim to proceed outside the Liquidation Court would result in iniquity by prioritizing DBP's claim over those of other creditors. The Court also clarified that the Liquidation Court has the authority under Section 30 of RA 7653 to adjudicate disputed claims and assist in the enforcement of individual liabilities of stockholders, directors, and officers, thus it can resolve the liabilities of Hermosa Bank's officers. On the writ of preliminary attachment: The Court held that with the dismissal of DBP's complaint, the writ of preliminary attachment, being a provisional remedy, no longer has a legal basis and should be dissolved.
Main Doctrine
A liquidation court has exclusive jurisdiction over all claims against a bank placed under receivership, even if the claim was filed before the bank's closure, to prevent multiplicity of suits and ensure orderly liquidation.