GR 226761; (July, 2020) (Digest)
G.R. No. 226761 & G.R. No. 226889, July 28, 2020
FIL-AGRO RURAL BANK, INC., THROUGH THE PHILIPPINE DEPOSIT INSURANCE CORP. (PDIC), AS LIQUIDATOR, PETITIONER, VS. ANTONIO J. VILLASEÑOR, JR., RESPONDENT. [G.R. No. 226889] ANTONIO J. VILLASEÑOR, JR., PETITIONER, VS. FIL-AGRO RURAL BANK, INC., THROUGH THE PHILIPPINE DEPOSIT INSURANCE CORP. (PDIC), AS LIQUIDATOR AND WILFREDA V. VILLASEÑOR, RESPONDENT.
FACTS
On June 23, 2014, Antonio J. Villaseñor, Jr. filed a complaint for Declaration of Nullity of Real Estate Mortgages and Quieting of Title with Damages before the RTC of Pasig City, seeking to nullify real estate mortgages executed by his wife, Wilfreda V. Villaseñor, in favor of Fil-Agro Rural Bank, Inc. over their conjugal properties without his knowledge and consent. During the pendency of the case, the Bangko Sentral ng Pilipinas placed Fil-Agro under the receivership of the Philippine Deposit Insurance Corporation (PDIC). The RTC of Malolos City was constituted as the liquidation court. The RTC Pasig set the case for pre-trial. Fil-Agro, through PDIC, filed motions related to the proceedings. On June 29, 2015, the RTC Pasig proceeded with the pre-trial conference despite a pending motion. Antonio appeared through counsel, while Wilfreda and Fil-Agro failed to appear and submit required briefs. The RTC declared them in default and allowed Antonio to present evidence ex parte. Fil-Agro’s subsequent Motion for Reconsideration was denied for being pro forma. Fil-Agro filed a Petition for Certiorari with the Court of Appeals. The CA, in its Decision, ordered the consolidation of the civil case with the liquidation proceedings before the RTC Malolos but sustained the RTC Pasig’s Orders declaring default and denying the motion for reconsideration. Both parties filed Petitions for Review on Certiorari before the Supreme Court.
ISSUE
1. Whether the consolidation of the civil case for annulment of real estate mortgage, quieting of title, and damages with the liquidation case is proper.
2. Whether the June 29, 2015 and September 28, 2015 Orders of the RTC Pasig are valid.
RULING
1. Yes, consolidation is proper. The Supreme Court ruled that upon Fil-Agro being placed under receivership and liquidation, the RTC Malolos, as the liquidation court, acquired exclusive jurisdiction to adjudicate all claims against the bank, pursuant to Section 30 of Republic Act No. 7653 (The New Central Bank Act). Antonio’s action for declaration of nullity of mortgage and quieting of title constitutes a “disputed claim” against the assets of the institution under liquidation. The assets of a bank under liquidation are deemed in custodia legis, and the liquidation court has jurisdiction over all claims for and against the bank, regardless of whether the properties involved have been foreclosed. Therefore, the RTC Pasig lost jurisdiction over the case, and consolidation with the liquidation proceedings is proper to prevent multiplicity of suits and ensure orderly liquidation.
2. No, the RTC Pasig Orders are not valid; they are null and void. The Supreme Court held that a judgment or order rendered by a court without jurisdiction is null and void. Since the RTC Pasig lost jurisdiction over the case upon the designation of the PDIC as receiver and the commencement of liquidation proceedings, its Orders dated June 29, 2015 (declaring default and allowing ex parte presentation of evidence) and September 28, 2015 (denying the motion for reconsideration) are void and of no legal effect. Consequently, the Court modified the CA Decision, affirming the order for consolidation but declaring the said RTC Pasig Orders null and void for lack of jurisdiction.
DISPOSITIVE:
The petition in G.R. No. 226889 (Antonio’s) was DENIED. The petition in G.R. No. 226761 (Fil-Agro’s) was GRANTED. The CA Decision was AFFIRMED with MODIFICATION in that the Orders dated June 29, 2015 and September 28, 2015 of the RTC Pasig were declared NULL and VOID for lack of jurisdiction.