G.R. No. L-29352 January 21, 1986
EMERITO M. RAMOS, ET AL., petitioners, vs. CENTRAL BANK OF THE PHILIPPINES, ET AL., respondents.

FACTS

This case originated from the financial collapse of the Overseas Bank of Manila (OBM), later renamed Commercial Bank of Manila (COMBANK). Under the management of the Ramos Group, OBM engaged in extensive irregularities from 1964 to 1967, diverting bank funds, including depositor money, to Ramos-owned entities. This led to chronic overdrawings on its clearing account with the Central Bank (CB), which provided emergency loans to keep OBM afloat. By December 1967, OBM’s indebtedness to CB for these advances reached approximately ₱46.6 million. The Monetary Board eventually placed OBM under a Voting Trust Agreement.
A subsequent Rehabilitation Plan involved the sale of the Ramos Group’s OBM shares to the IUCP Group. A critical condition of this plan, approved by the CB, was that OBM (later COMBANK) would assume liability for the principal of the CB advances but would be absolved from paying the accrued interest, estimated at ₱47 million. The CB later sought to recover this interest from COMBANK, leading to litigation. The Supreme Court, in a Resolution dated October 19, 1982, upheld COMBANK’s non-liability for the interest. The CB filed motions for reconsideration, which were denied.

ISSUE

The core legal issue is whether the Central Bank’s second motion for reconsideration should be granted, effectively revisiting the Court’s final ruling that COMBANK is not liable for the interest on the emergency loans.

RULING

The Court, en banc, resolved to DENY the Central Bank’s separate motions for leave to file and to admit a second motion for reconsideration. The denial was due to a lack of the necessary votes to grant the motions, not a substantive reaffirmation of the prior ruling’s legal merits. The resolution directed the entry of final judgment on the October 19, 1982 ruling.
The voting was split, highlighting the case’s contentious nature. Chief Justice Aquino, in a vigorous dissent, argued for granting the motion in the interest of justice. He extensively quoted the CB’s first motion for reconsideration, which contended that the Court’s initial resolution failed to squarely address the issues. The CB’s position emphasized the principle of the inviolability of contracts, noting the parties’ original agreement for interest payment, and principles of equity. It argued that COMBANK, having profited from the CB’s financial assistance that saved it from liquidation, should not be allowed to renege on its interest obligation. The dissent painted a picture of profound inequity, where the Ramos Group, whose irregularities caused the bank’s failure, benefited immensely from the rehabilitation terms, while the CB (using public funds) and OBM’s innocent depositors and creditors bore the losses. Despite these compelling equitable arguments raised in the dissent, the Court’s procedural vote resulted in the finality of the judgment favoring COMBANK’s exemption from the interest liability.