G.R. No. 234401 , December 05, 2019
Connie L. Servo, Petitioner vs. Philippine Deposit Insurance Corporation, Respondent

FACTS

Petitioner Connie L. Servo filed a claim for deposit insurance with respondent Philippine Deposit Insurance Corporation (PDIC). She alleged that she lent money to Teresita Guiterrez, and on January 19, 2012, they met at the Rural Bank of San Jose Del Monte for Guiterrez to make a loan payment. Petitioner opened a time deposit account (Special Savings Deposit Account No. 001 03-00904-1) at the bank, but per her agreement with Guiterrez, Guiterrez’s name was used as the account holder because she was a preferred bank client. Petitioner claimed she verbally informed a bank teller that the money deposited was held in trust for her by Guiterrez and that she was the exclusive owner of the account. When the bank later closed, petitioner filed her insurance claim. PDIC denied the claim initially due to the absence of bank records showing petitioner owned the account, and later, upon reconsideration, due to petitioner’s failure to submit documents showing a valid consideration for the transfer and because petitioner was not a relative of Guiterrez within the second degree. Petitioner filed a petition with the Regional Trial Court (RTC), imputing grave abuse of discretion to PDIC. The RTC dismissed the case for lack of jurisdiction, ruling that since PDIC performed a quasi-judicial action, the case should have been brought to the Court of Appeals. Petitioner then filed a special civil action for certiorari with the Court of Appeals. The Court of Appeals dismissed the petition for lack of jurisdiction, ruling that the pure legal question involved should have been filed directly with the Supreme Court under Rule 45.

ISSUE

Did the Court of Appeals err in dismissing the petition for certiorari on the ground of lack of jurisdiction?

RULING

Yes, the Court of Appeals erred in dismissing the petition for certiorari on the ground that it involved a pure question of law falling within the Supreme Court’s exclusive jurisdiction. Under Section 9 of Batas Pambansa Bilang 129, the Court of Appeals has original jurisdiction to issue writs of certiorari, and this jurisdiction is concurrent with the Regional Trial Courts and the Supreme Court. The law does not distinguish based on whether the issues are factual, legal, or mixed. Furthermore, the doctrine of hierarchy of courts generally dictates that petitions for extraordinary writs against first-level courts should be filed with the RTC, and those against the RTC, with the Court of Appeals. However, the Court also noted that under Section 5(g) of Republic Act No. 3591 (the PDIC Charter), as amended by Republic Act No. 10846 , actions of the PDIC are final and executory and may only be restrained or set aside by the Court of Appeals through a petition for certiorari filed within thirty days. In this case, the Court of Appeals ultimately did not have to rule on the merits because petitioner’s petition was filed more than two years after PDIC’s denial of her claim, well beyond the thirty-day reglementary period. Therefore, while the Court of Appeals had jurisdiction over the petition for certiorari, it could not act on it due to the late filing. The Supreme Court denied the petition.