GR 173399; (February, 2017) (Digest)
G.R. No. 173399 February 21, 2017
CENTRAL BANK BOARD OF LIQUIDATORS, Petitioner, vs. BANCO FILIPINO SAVINGS AND MORTGAGE BANK, Respondent.
FACTS
Banco Filipino filed a series of complaints against the Central Bank (CB) and its Monetary Board (MB) in the 1980s, challenging orders placing the bank under conservatorship, receivership, and liquidation. These cases were consolidated. In 1993, Republic Act No. 7653 abolished the CB and created the Bangko Sentral ng Pilipinas (BSP) and the petitioner Central Bank Board of Liquidators (CB-BOL). In 1995, the trial court admitted Banco Filipino’s Amended/Supplemental Complaint, substituting the CB-BOL for the defunct CB. Subsequently, in 2003, Banco Filipino filed a Motion to Admit a Second Amended/Supplemental Complaint seeking to include the BSP and its MB as additional defendants. This new pleading alleged new acts by the BSP and MB occurring nearly a decade after the original complaint, including refusal to grant a universal banking license, engaging in a smear campaign, and conspiring with minority stockholders.
ISSUE
Whether the trial court and the Court of Appeals erred in admitting the Second Amended/Supplemental Complaint, which sought to implead new parties (BSP and its MB) and introduce new causes of action based on facts that arose long after the filing of the original complaint.
RULING
The Supreme Court ruled that the trial court gravely abused its discretion in admitting the Second Amended/Supplemental Complaint. The Court emphasized that a supplemental complaint is governed by Section 6, Rule 10 of the Rules of Court, which permits a party to set forth transactions, occurrences, or events that have happened since the date of the pleading sought to be supplemented. The purpose is to update the original complaint with subsequent facts related to the original cause of action. Here, the new allegations against the BSP and its MB pertained to entirely distinct acts and omissions that transpired approximately ten years after the original complaint was filed. These new claims did not supplement the original cause of action concerning the illegal closure of the bank in 1985. Instead, they constituted entirely new and independent causes of action. Furthermore, the BSP is a distinct juridical entity from the old CB, and the CB-BOL is the proper party-liquidator for claims against the abolished CB. Impleading the BSP and its MB would violate rules on joinder of parties and causes of action, as the new defendants and claims did not arise from the same transaction or series of transactions as the original suit. The admission of the pleading would unfairly prejudice the new parties by holding them liable for acts not originally litigated.