The Supreme Court ruled that the Court of Appeals, not the Regional Trial Court, has jurisdiction over petitions challenging actions by the Philippine Deposit Insurance Corporation (PDIC) regarding deposit insurance claims. This decision clarifies the procedural route for claimants seeking to contest PDIC’s decisions, emphasizing the need to file a petition for certiorari with the Court of Appeals within thirty days of a claim denial. This ensures a streamlined and specialized review process for deposit insurance disputes.

Navigating the Hierarchy: Servo’s Quest for Deposit Insurance and the Jurisdictional Maze

Connie L. Servo sought to recover a P500,000 deposit insured by the PDIC. Servo claimed she lent money to Teresita Guiterrez, which was then deposited in a time deposit account at the Rural Bank of San Jose Del Monte. However, the account was under Guiterrez’s name, purportedly because she was a preferred client. When the bank closed, PDIC denied Servo’s claim due to the lack of documentation showing Servo as the account owner. Servo then filed an action against PDIC in the Regional Trial Court (RTC), alleging grave abuse of discretion. PDIC countered that the RTC lacked jurisdiction, arguing the case fell under its quasi-judicial authority. The RTC agreed with PDIC and dismissed the case. The Court of Appeals also dismissed Servo’s subsequent petition for lack of jurisdiction, stating the issue was a pure question of law for the Supreme Court. The central legal question was whether the Court of Appeals erred in dismissing the petition for certiorari on jurisdictional grounds.

The Supreme Court held that the Court of Appeals indeed erred in dismissing Servo’s petition. The Court clarified that Section 9 of Batas Pambansa Bilang 129 (BP 129) grants concurrent jurisdiction to Regional Trial Courts, the Court of Appeals, and the Supreme Court over special civil actions and auxiliary writs. The law does not differentiate based on whether the issues are purely factual, legal, or mixed when determining which court should handle the case. The Court emphasized the hierarchy of courts, noting that while it shares jurisdiction with the Court of Appeals, direct resort to the Supreme Court should only occur for special and important reasons.

The Court referenced the doctrine established in Gios – Samar, Inc., etc. v. Department of Transportation and Communications, et al., stating that the Court of Appeals has the original jurisdiction to issue writs of mandamus, prohibition, certiorari, habeas corpus, and quo warranto. Furthermore, the Supreme Court cited Saint Mary Crusade to Alleviate Poverty of Brethren Foundation, Inc. v. Judge Riel, which reinforced the importance of adhering to the hierarchy of courts to avoid overburdening the Supreme Court with unnecessary cases.

However, to expedite the resolution, the Supreme Court decided not to remand the case to the Court of Appeals. Instead, the Court directly addressed the jurisdictional issue involving PDIC. The Court noted that when Servo initiated her action for certiorari, Republic Act (RA) 10846, which amended RA 3591 (PDIC Charter), was already in effect. Therefore, Servo should have complied with the procedures outlined in RA 10846, which grants exclusive original jurisdiction to the Court of Appeals over matters involving bank deposits and insurance.

Section 5(g) of RA 3591, as amended by RA 10846, explicitly states that actions by PDIC regarding insured deposits and deposit liabilities can only be challenged before the Court of Appeals through a Petition for Certiorari under Rule 65 of the Revised Rules of Court. This petition must be filed within thirty days from the notice of denial of the deposit insurance claim. The provision reads:

SECTION 7. Section 4 of the same Act is accordingly renumbered as Section 5, and is hereby amended to read as follows:

DEFINITION OF TERMS

SEC. 5. As used in this Act-

X X X X

(g) XXX XXX XXX XXX

The actions of the Corporation taken under Section 5(g) shall be final and executory, and may only be restrained or set aside by the Court of Appeals, upon appropriate petition for certiorari on the ground that the action was taken in excess of jurisdiction or with such grave abuse of discretion as to amount to a lack or excess of jurisdiction. The petition for certiorari may only be filed within thirty(30) days from notice of denial of claim for deposit insurance.

The Supreme Court also referenced Peter L. So v. Philippine Deposit Insurance Corp., emphasizing that the Court of Appeals is vested with jurisdiction over matters relating to PDIC dispositions. The Court quoted the decision:

Clearly, a petition for certiorari, questioning the PDIC’s denial of a deposit insurance claim should be filed before the CA, not the RTC. This further finds support in Section 22 of the PDIC’s Charter, as amended, which states that Section 22. No court, except the Court of Appeals, shall issue any temporary restraining order, preliminary injunction or preliminary mandatory injunction against the Corporation for any action under this Act. x x x.

The Court rejected Servo’s alternative argument that the Court of Appeals should have treated her petition as an original action against the PDIC dispositions. The Court noted that Servo’s petition was filed beyond the thirty-day reglementary period prescribed under RA 10846. Servo’s Request for Reconsideration (RFR) was denied on July 16, 2015, but she filed her petition for certiorari with the Court of Appeals only on September 7, 2017, more than two years after PDIC’s denial. Consequently, the Court found that there was nothing more for the Court of Appeals to act on, as the trial court’s ruling had already lapsed into finality.

FAQs

What was the key issue in this case?	The central issue was determining which court had jurisdiction to review the denial of a deposit insurance claim by the Philippine Deposit Insurance Corporation (PDIC). The case specifically addressed whether the Regional Trial Court (RTC) or the Court of Appeals (CA) was the proper venue for a petition for certiorari challenging PDIC’s decision.
What did the Supreme Court decide regarding jurisdiction over PDIC actions?	The Supreme Court ruled that the Court of Appeals, not the Regional Trial Court, has jurisdiction over petitions challenging actions by the PDIC related to deposit insurance claims. This decision clarified that any challenges to PDIC’s decisions must be filed with the Court of Appeals via a petition for certiorari.
What is a petition for certiorari?	A petition for certiorari is a legal action filed to request a higher court to review the decision of a lower court or quasi-judicial body. It is typically based on the argument that the lower entity acted with grave abuse of discretion or exceeded its jurisdiction.
What is the reglementary period for filing a petition for certiorari against PDIC?	According to Republic Act (RA) 10846, amending the PDIC Charter, a petition for certiorari against PDIC’s decision must be filed within thirty (30) days from the notice of denial of the claim for deposit insurance. This strict timeline is crucial for claimants to adhere to.
What was the basis for PDIC denying Connie Servo’s claim?	PDIC denied Connie Servo’s claim because the bank records did not indicate that she, rather than Teresita Guiterrez, owned the account. The absence of documentation linking Servo to the account ownership was the primary reason for the denial.
Why did the Court of Appeals initially dismiss Servo’s petition?	The Court of Appeals initially dismissed Servo’s petition for lack of jurisdiction, stating that the issue involved a pure question of law that should have been filed with the Supreme Court. However, the Supreme Court corrected this, clarifying the Court of Appeals’ jurisdiction over such petitions.
What is the significance of Republic Act 10846 in this case?	Republic Act 10846, which amended the PDIC Charter, is significant because it explicitly grants the Court of Appeals exclusive original jurisdiction over actions challenging PDIC’s decisions. This law clarifies the procedural route for deposit insurance disputes.
Could Servo’s petition be treated as an original action against PDIC’s decision?	No, the Supreme Court ruled that Servo’s petition could not be treated as an original action because it was filed beyond the thirty-day reglementary period prescribed under RA 10846. The delay in filing made it impossible for the Court of Appeals to act on the petition.

This case underscores the importance of understanding jurisdictional rules and adhering to prescribed timelines when challenging decisions made by quasi-judicial agencies like the PDIC. Claimants must ensure they file their petitions with the correct court and within the specified period to preserve their right to seek redress.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Connie L. Servo v. PDIC, G.R. No. 234401, December 05, 2019