GR 137786; (March, 2004) (Digest)
G.R. No. 137786 ; March 17, 2004
MARTIN B. ROSARIO, ET AL., petitioners, vs. PHILIPPINE DEPOSIT INSURANCE CORPORATION, ET AL., respondents.
FACTS
Petitioners, numerous depositors of the Rural Bank of Alcala, Pangasinan, Inc., filed a Complaint for Sum of Money with Damages against the Philippine Deposit Insurance Corporation (PDIC) and individual bank officers and stockholders. They alleged that after being enticed by high interest rates, they placed time deposits with the bank. The bank later failed, and their claims were not fully satisfied. They asserted that the individual respondents caused the bank’s insolvency by granting fictitious loans to themselves and other fictitious persons, thereby defrauding the depositors. The bank was ordered closed and placed under PDIC receivership, and later under liquidation by the Monetary Board.
The Regional Trial Court (RTC) of San Carlos City dismissed the case for lack of jurisdiction. It ruled that exclusive jurisdiction over claims against the bank lay with the RTC of Villasis, Pangasinan, which was overseeing the bank’s liquidation proceedings initiated by PDIC. The Court of Appeals affirmed this dismissal. Petitioners then filed a Motion for Reconsideration with the Court of Appeals, which was denied. They subsequently elevated the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Whether the Supreme Court can take cognizance of the petition and resolve the substantive issues regarding the dismissal of the complaint against the bank officers and stockholders.
RULING
No. The Supreme Court dismissed the petition on procedural grounds, thereby precluding a resolution of the substantive merits. The Court found that the petitioners’ Motion for Reconsideration of the Court of Appeals’ Decision was filed out of time. The appellate court’s records showed that a copy of its Decision was received at the address of petitioners’ counsel on October 12, 1998. The 15-day period to file a motion for reconsideration thus expired on October 27, 1998. However, petitioners filed their motion only on November 4, 1998, erroneously computing the period from the date their counsel allegedly saw the copy. Consequently, the Court of Appeals’ Decision had already become final and executory when the motion was filed.
Since the assailed Decision had attained finality, the Supreme Court no longer had jurisdiction to review it. The Court emphasized that the reglementary periods for appeal are mandatory and jurisdictional. Furthermore, the Court noted that the petition for review itself was procedurally infirm for failure to accompany it with the required duplicate original or certified true copy of the assailed judgments and for lacking proof of service, which are independent grounds for dismissal under Rule 45 of the Rules of Court.