G.R. No. 230020 . March 19, 2018
PETER L. SO, PETITIONER, V. PHILIPPINE DEPOSIT INSURANCE CORPORATION, RESPONDENT.

FACTS

Petitioner Peter L. So opened a Special Incentive Savings Account with the Cooperative Rural Bank of Bulacan (CRBB) in 2013. Subsequently, CRBB was closed and placed under the receivership of the Philippine Deposit Insurance Corporation (PDIC). So filed a claim for deposit insurance with the PDIC. Upon investigation, the PDIC found that So’s account was funded by the proceeds of a terminated joint account owned by another family. The PDIC determined that this constituted an illegal splitting of deposits, a scheme to maximize deposit insurance coverage beyond legal limits, and consequently denied So’s insurance claim. So’s request for reconsideration was also denied.
Aggrieved, So filed a Petition for Certiorari under Rule 65 before the Regional Trial Court (RTC) of Makati, assailing the PDIC’s denial as having been rendered with grave abuse of discretion. The RTC dismissed the petition for lack of jurisdiction. It ruled that the PDIC, in evaluating and deciding deposit insurance claims, exercises quasi-judicial functions. Consequently, under Section 4, Rule 65 of the Rules of Court, a certiorari petition assailing the acts of a quasi-judicial agency is cognizable only by the Court of Appeals. The RTC also cited Section 22 of Republic Act No. 3591 (the PDIC Charter), as amended, which provides that only the Court of Appeals can issue injunctive relief against the PDIC.

ISSUE

Does the Regional Trial Court have jurisdiction over a petition for certiorari filed under Rule 65, assailing the PDIC’s denial of a deposit insurance claim?

RULING

No, the Regional Trial Court does not have jurisdiction. The Supreme Court denied the petition and affirmed the RTC’s dismissal. The Court clarified that while Section 4(f) of the PDIC Charter allows a certiorari petition to question a final insurance claim denial on grounds of excess of jurisdiction or grave abuse of discretion, the specific court with jurisdiction is definitively settled by law.
The PDIC, in performing its statutory duty to determine the validity of deposit insurance claims, exercises quasi-judicial authority. Its actions in this regard are final and executory. The legislative intent to confer quasi-judicial status is clear from its Charter and related regulations. Following the rule that certiorari petitions against quasi-judicial agencies are cognizable by the Court of Appeals, the RTC correctly declined jurisdiction. This conclusion is expressly confirmed by Section 5(g) of Republic Act No. 10846 , which amended the PDIC Charter to explicitly state that such certiorari petitions may only be restrained or set aside by the Court of Appeals. Therefore, the proper remedy for the petitioner was to file the petition directly with the Court of Appeals within the prescribed period.