G.R. No. 200642 , April 26, 2021
BANCO FILIPINO SAVINGS AND MORTGAGE BANK, PETITIONER, VS. BANGKO SENTRAL NG PILIPINAS AND THE MONETARY BOARD, RESPONDENTS.

FACTS

Banco Filipino is a banking institution ordered closed in 1985, a closure later declared void by the Supreme Court in 1991. The Bangko Sentral ng Pilipinas (BSP) and the Monetary Board (MB) are the central monetary authority. Banco Filipino, after resuming business, suffered heavy withdrawals and sought financial assistance from BSP. It submitted a Long-Term Business Plan, which underwent several revisions. An Ad Hoc Committee produced an Alternative Business Plan. The Monetary Board, via Resolution No. 1668 dated December 4, 2009, approved a P25-billion Financial Assistance and Regulatory Reliefs package, subject to conditions including the withdrawal or dismissal with prejudice of all pending cases filed by Banco Filipino against BSP and its officials, and the execution of quitclaims and commitments not to refile such cases. Banco Filipino objected to this condition, leading to a breakdown in negotiations. Banco Filipino then filed a Petition for Certiorari and Mandamus with prayer for a Temporary Restraining Order (TRO) and Writ of Preliminary Injunction (WPI) before the Regional Trial Court (RTC) of Makati, alleging grave abuse of discretion by respondents in imposing the condition. The RTC granted the TRO and later the WPI. The Court of Appeals set aside the RTC’s issuance of the TRO and WPI. Banco Filipino elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals correctly set aside the RTC’s issuance of the temporary restraining order and writ of preliminary injunction.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals Decision. The RTC committed grave abuse of discretion in issuing the TRO and WPI. The issuance was improper because Banco Filipino failed to establish a clear and unmistakable right to the injunctive relief. The approval of the financial assistance package was conditional, and Banco Filipino’s refusal to accept the condition (withdrawal of cases) meant no final agreement was reached. Furthermore, the RTC had no jurisdiction to issue an injunction that would interfere with the BSP’s and MB’s exercise of their supervisory and regulatory powers under the New Central Bank Act. The BSP’s acts were performed in the exercise of its governmental functions and within its exclusive authority. The condition imposed was a valid exercise of the BSP’s discretion and was not unlawful, as it aimed for a complete settlement and was related to the financial assistance being a form of extraordinary relief. The Supreme Court also noted that the RTC’s injunction effectively compelled the BSP to release funds without conditions, which was a prejudgment of the main case and an encroachment on the BSP’s monetary and banking policy functions.