GR 184778; (October, 2009) (Digest)
G.R. No. 184778; October 2, 2009
BANGKO SENTRAL NG PILIPINAS MONETARY BOARD and CHUCHI FONACIER, Petitioners, vs. HON. NINA G. ANTONIO-VALENZUELA, in her capacity as Regional Trial Court Judge of Manila, Branch 28; RURAL BANK OF PARAÑAQUE, INC.; et al., Respondents.
FACTS
The Bangko Sentral ng Pilipinas (BSP) examined several rural banks and found deficiencies. The banks were furnished Lists of Findings and directed to undertake remedial measures, including capital infusion, within 30 days. The banks claimed compliance, but BSP, through petitioner Chuchi Fonacier, informed them they had failed. The banks requested more time, disclosure of the basis for the capital figures, and a copy of the final Report of Examination (ROE), which they had not received. They also sought meetings to reconcile audit figures. Fonacier reiterated the finding of non-compliance.
Subsequently, the Rural Bank of Parañaque, Inc. (RBPI) filed a complaint before the Regional Trial Court (RTC) to nullify the ROE and to enjoin its submission to the Monetary Board, or to enjoin the Board from acting on it, alleging a due process violation for not being furnished a copy. Several other examined banks filed substantially similar complaints. The RTC, through respondent Judge Valenzuela, issued temporary restraining orders (TROs) and later consolidated the cases. Petitioners BSP and Fonacier moved for dismissal and challenged the consolidation and the injunctive relief.
ISSUE
Whether the Regional Trial Court gravely abused its discretion in issuing writs of preliminary injunction to restrain the BSP and its officials from submitting the Report of Examination to the Monetary Board.
RULING
Yes, the RTC committed grave abuse of discretion. The Supreme Court ruled that the issuance of the injunctive writs was a patent nullity for violating the doctrine of primary jurisdiction and the specific, exclusive procedures under the New Central Bank Act (R.A. No. 7653). The power to conduct examinations and act on their findings is vested exclusively in the BSP and its Monetary Board. The law provides a clear administrative remedy: the banks must first submit their comments on the findings to the Monetary Board, which will then decide on the appropriate action, including possible receivership or liquidation.
Crucially, Section 30 of R.A. No. 7653 states that any action taken by the Monetary Board under these provisions is “final and executory” and “may not be restrained or set aside by the court except on petition for certiorari” filed by stockholders on specific grounds. The banks’ premature resort to the RTC, seeking to enjoin the very process of submitting the report for the Board’s evaluation, circumvented this exclusive statutory framework. The RTC’s orders effectively interfered with the BSP’s regulatory functions at a preliminary stage, disrupting an ongoing administrative process designed by law to be summary and non-dilatory. Therefore, the injunctions were issued without legal basis.