G.R. No. 230037. March 19, 2018.
SPOUSES KISHORE LADHO CHUGANI AND PRISHA KISHORE CHUGANI, ET AL., PETITIONERS, V. PHILIPPINE DEPOSIT INSURANCE CORPORATION, RESPONDENT.

FACTS

Petitioners opened time deposit accounts with the Rural Bank of Mawab (Davao), Inc. (RBMI) upon the invitation of its president, Raymundo Garan. They executed signature cards and submitted funds via inter-branch deposits to RBMI’s accounts in other banks, subsequently receiving Certificates of Time Deposit (CTDs) and official receipts. In September 2011, the Bangko Sentral ng Pilipinas placed RBMI under receivership and later closed it. Petitioners then filed claims for deposit insurance with the Philippine Deposit Insurance Corporation (PDIC).
The PDIC denied the claims, asserting that based on RBMI’s official records, the petitioners’ accounts were not part of the bank’s deposit liabilities. It ruled the deposits were fraudulent, the CTDs were mere replicas of unissued forms, and the deposited amounts were credited to Garan’s personal account, not to RBMI. After their motion for reconsideration was denied, petitioners filed a Petition for Certiorari under Rule 65 with the Regional Trial Court (RTC) of Makati, challenging the PDIC’s denial as a grave abuse of discretion. The RTC dismissed the petition for lack of jurisdiction, a ruling affirmed by the Court of Appeals.

ISSUE

Whether the Regional Trial Court correctly dismissed the Petition for Certiorari for lack of jurisdiction over the acts of the PDIC.

RULING

Yes, the RTC correctly dismissed the petition for lack of jurisdiction. The Supreme Court affirmed the rulings of the lower courts, holding that the PDIC is a quasi-judicial agency when it exercises its statutory power to adjudicate claims for deposit insurance. Under its amended charter (Republic Act No. 3591, as amended by R.A. No. 9576), the PDIC’s actions on insurance claims are declared “final and executory,” reviewable only by a petition for certiorari filed within thirty days from notice of denial. Critically, Section 4(f) of the law specifies that such a petition for certiorari may be filed to challenge an action taken “in excess of jurisdiction or with such grave abuse of discretion.”
The procedural rule governing this remedy is explicit. Section 4, Rule 65 of the Rules of Court mandates that if a certiorari petition “involves the acts or omissions of a quasi-judicial agency, unless otherwise provided by law or these rules, the petition shall be filed with and be cognizable only by the Court of Appeals.” Since the PDIC is a quasi-judicial agency in this context, and no law provides an exception, the Court of Appeals possesses exclusive original jurisdiction over certiorari petitions assailing its final orders. Consequently, the RTC of Makati had no jurisdiction to entertain the petition. The Supreme Court did not reach the substantive issue of whether PDIC committed grave abuse of discretion, as the threshold issue of jurisdiction was fatal to the petitioners’ case. The denial of the petition was therefore proper.