GR 154356; (April, 2007) (Digest)
G.R. No. 154356; April 11, 2007
BANGKO SENTRAL NG PILIPINAS and THE MEMBERS OF THE MONETARY BOARD, Petitioners, vs. RURAL BANK OF SAN MIGUEL (BULACAN), INC., represented by HILARIO P. SORIANO, President and Principal Stockholder, Respondent.
FACTS
Hilario P. Soriano, representing Rural Bank of San Miguel (RBSM), filed an administrative complaint with the Bangko Sentral ng Pilipinas (BSP) against several BSP officials for alleged unprofessionalism. The BSP’s Monetary Board created an Ad-Hoc Committee, which investigated and recommended the dismissal of the complaint. The Monetary Board adopted this recommendation and absolved the officials. After its motion for reconsideration was denied, RBSM filed a petition for review with the Court of Appeals (CA) under Rule 43 of the Rules of Court. In its petition, RBSM impleaded not only the individual BSP officials but also the BSP itself and the Members of the Monetary Board as public respondents.
The CA reversed the Monetary Board’s resolution and found the BSP officials administratively liable. The BSP and the Monetary Board then filed the present petition for review before the Supreme Court. Meanwhile, the individual BSP officials separately appealed the CA decision in G.R. No. 154499. The Supreme Court, in that separate case, had already modified the CA ruling, reducing the penalties on some officials and absolving another, and that decision had become final and executory.
ISSUE
Whether the Bangko Sentral ng Pilipinas and the Members of its Monetary Board were properly impleaded as respondents in the petition for review filed with the Court of Appeals.
RULING
The Supreme Court granted the petition in part, ruling that the BSP and the Monetary Board should not have been impleaded as respondents. The legal logic is grounded in procedural rules governing appeals from quasi-judicial agencies. Section 6, Rule 43 of the Rules of Court explicitly provides that a petition for review shall state the full names of the parties to the case “without impleading the court or agencies either as petitioners or respondents.” The BSP, through its Monetary Board, is the administrative agency that rendered the decision being appealed. The rule is clear that the agency itself should not be named as a party in an appeal from its own decision. The proper parties are the adverse parties in the administrative case.
The Court noted that the substantive issue regarding the administrative liability of the individual BSP officials had already been resolved with finality in the related case, G.R. No. 154499. Therefore, the only remaining procedural issue was the improper joinder of the institutional petitioners. The Court emphasized that, in any event, no relief was granted against the BSP and the Monetary Board in the CA decision; they were treated as mere nominal parties. Their inclusion was a procedural error that warranted their exclusion from the case.