Hermosa Savings and Loan Bank, Inc. vs. Development Bank of the Philippines

The Liquidation Court has exclusive jurisdiction over all claims against a closed bank, including claims against its officers' liabilities, notwithstanding the pendency of a prior civil action in a regular court filed before the bank's closure.

DBP obtained funds from the Industrial Guarantee and Loan Fund (IGLF) and made subsidiary loans available to participating financial institutions. Hermosa Bank was accredited by DBP and executed subsidiary loan agreements; it thereafter borrowed IGLF funds and submitted corresponding loan documents and collaterals to DBP. A BSP regular examination later raised suspicions of tampering and falsification of loan and title documents in Hermosa Bank's portfolio, prompting DBP to pursue recovery of unpaid subsidiary loans.

DBP obtained funds from the Industrial Guarantee and Loan Fund (IGLF) and made subsidiary loans available to participating financial institutions. Hermosa Bank was accredited by DBP and executed subsidiary loan agreements; it thereafter borrowed IGLF funds and submitted corresponding loan documents and collaterals to DBP. DBP alleged that Hermosa Bank failed to remit amortizations and that the subsidiary loans were in default. A BSP regular examination later raised suspicions of tampering and falsification of loan and title documents in Hermosa Bank's portfolio.

On September 25, 2001, DBP filed a complaint for sum of money and damages against Hermosa Bank and several bank officers — sued personally — in RTC Branch 136, Makati City (Civil Case No. 01-1438), and sought an ex parte writ of preliminary attachment, which the trial court issued on November 13, 2001. The writ was lifted in 2003 but later reinstated pursuant to an earlier Court of Appeals decision. DBP's pleaded aggregate claim as of June 30, 2001 was approximately P438.2 million.

On February 5, 2005, the Monetary Board closed Hermosa Bank and designated PDIC as receiver. PDIC filed, on June 7, 2005, a petition for assistance in the liquidation of Hermosa Bank in Branch 5, RTC, Dinalupihan, Bataan (the Liquidation Court). The bank's counsel withdrew and PDIC's Office of the General Counsel appeared for the bank. The bank officers and Hermosa Bank moved to dismiss the RTC Branch 136 complaint on grounds that Section 30 of Republic Act No. 7653 (the New Central Bank Act) vested exclusive jurisdiction in the Liquidation Court.

RTC Branch 136 initially dismissed the DBP complaint in October 2008, reinstated it in March 2009, and then, in an Order dated April 30, 2010, again dismissed the complaint for lack of jurisdiction in favor of the Liquidation Court. The case was re-raffled to RTC Branch 57 and, in an Order dated October 18, 2011, Branch 57 denied DBP's motion for reconsideration and maintained dismissal, holding that Hermosa Bank's assets were in custodia legis and that claims must be pursued in the Liquidation Court. DBP appealed to the Court of Appeals.

In CA G.R. CV No. 98170, the CA, in a Decision penned by Associate Justice Ramon M. Bato, Jr. (Feb. 26, 2015), reversed and set aside the RTC orders, holding that the RTC retained jurisdiction because DBP's case had been pending since 2001 (before receivership) and because the complaint included claims against individual bank officers. The Supreme Court thereafter reversed the CA, ruling that the Liquidation Court has exclusive jurisdiction over claims against the closed bank, including officers' liabilities, and dismissing DBP's complaint.

• Exclusive Jurisdiction of the Liquidation Court: Petitioner argued that Section 30 of Republic Act No. 7653 (the New Central Bank Act) vested exclusive jurisdiction in the Liquidation Court over all claims against Hermosa Bank, and that the regular RTC therefore lacked jurisdiction to continue hearing DBP's complaint.
• Assets in Custodia Legis: Petitioner maintained that Hermosa Bank's assets were in custodia legis upon the bank's closure and the filing of the liquidation petition, and that all claims must be pursued in the Liquidation Court.

• Prior Pending Case: Respondent argued that the RTC retained jurisdiction because DBP's case had been pending since 2001, before the bank's closure and receivership in 2005.
• Claims Against Individual Officers: Respondent contended that the complaint included claims against individual bank officers sued personally, which purportedly placed those claims outside the Liquidation Court's exclusive jurisdiction.

• Jurisdiction of the Regular RTC: Whether RTC Branch 136 and RTC Branch 57 retained jurisdiction over DBP's complaint despite the pendency of the petition for assistance in the liquidation of Hermosa Bank before the Liquidation Court.
• Scope of Liquidation Court Jurisdiction: Whether the Liquidation Court's exclusive jurisdiction extends to claims against the closed bank's officers sued personally, or is limited only to claims against the bank itself.

• Jurisdiction of the Regular RTC: No. The regular RTC did not retain jurisdiction over DBP's complaint; exclusive jurisdiction vested in the Liquidation Court pursuant to Section 30 of Republic Act No. 7653.
• Scope of Liquidation Court Jurisdiction: No. The Liquidation Court's exclusive jurisdiction extends to claims against the closed bank's officers' liabilities as well, not merely to claims against the bank itself.

• Section 30, Republic Act No. 7653 (The New Central Bank Act) — Cited by petitioner as the statutory basis vesting exclusive jurisdiction in the Liquidation Court over all claims against a closed bank. The provision was applied to override the regular RTC's jurisdiction over DBP's complaint, which had been pending before the bank's closure, and to encompass claims against the bank's officers sued personally.