REPUBLIC OF THE PHILIPPINES

SUPREME COURT
MANILA

CONNIE L. SERVO,
Petitioner,

-vs-

PHILIPPINE DEPOSIT
INSURANCE CORPORATION,
Respondent.
x--------------------------------------------------------------------------------x

PETITION FOR REVIEW

ON CERTIORARI
Petitioner CONNIE L. SERVO, through counsel, and unto this
Honorable Court, respectfully files the instant petition under Rule
45 of the Rules of Court to assail the Resolution dated
September 22, 2017 of the Court of Appeals in CA-G.R. SP No.
152398.

PREFATORY

“[W]hen there exists meritorious grounds to overlook

strict procedural matters, the Court cannot turn a blind eye
thereto lest the administration of justice be derailed by an overly
stringent application of the rules. Rules of procedure are meant
to be tools to facilitate a fair and orderly conduct of proceedings.
Strict adherence thereto must not get in the way of achieving
substantial justice. As long as their purpose is sufficiently met
and no violation of due process and fair play takes place, the
Petition for Certiorari on Certiorari
Servo vs. PDIC

rules should be liberally construed. Dismissal of appeals purely

on technical grounds is frowned upon where the policy of the
court is to encourage hearings of appeals on their merits and the
rules of procedure ought not to be applied in a very rigid,
technical sense; rules of procedure are used only to help secure,
not override substantial justice. It is a far better and more
prudent course of action for the court to excuse a technical lapse
and afford the parties a review of the case on appeal to attain
the ends of justice rather than dispose of the case on
technicality and cause a grave injustice to the parties, giving a
false impression of speedy disposal of cases while actually
resulting in more delay, if not a miscarriage of justice . ”1

STATEMENT OF MATERIAL DATES

On September 29, 2017, petitioner, through counsel,

received a copy of the Court of Appeals Resolution dated
September 22, 2017.

An original duplicate copy of the said Resolution is hereto

attached as Annex “A”.

The instant petition is being filed within the 15-day

reglementary period provided for under Rule 45 of the Rules of
Court.

THE PARTIES

Petitioner CONNIE L. SERVO is of legal age, Filipino, and

with residence address at 250 North Diamond Subdivision, Brgy.
Maharlika, San Jose Del Monte 3023, Bulacan.

Private respondent Philippine Deposit Insurance Corporation

(PDIC) is a government corporation with office address at SSS
Bldg., 6782 Ayala Avenue corner Rufino Street, Makati City.

1
Morillo vs. People and Natividad, G.R. No. 198270, December 9, 2015.
Petition for Certiorari on Certiorari
Servo vs. PDIC

BRIEF STATEMENT OF THE FACTS OF THE CASE

Sometime in October 2011, petitioner Connie L. Servo

(petitioner) lent Teresita C. Gutierrez five hundred thousand
pesos (P500,000.00) for the repair of the latter's buses to keep
her public transport business in regular and continuous
operation. On January 19, 2012, petitioner met with Teresita at
the Rural Bank of San Jose Del Monte (bank) in order to settle
the loan. Instead of taking the payment in cash or check,
petitioner decided to open a time deposit account so that her
money would earn interest. Petitioner agreed that the Special
Savings Deposit (SSD) Account No. 001 03-00904-1 be placed in
the name of Teresita, a preferred client of the bank, in order to
enjoy higher interest rates and also for the latter to be able to
closely monitor her account.

Upon closure of the bank, petitioner filed before the

Philippine Deposit Insurance Corporation (PDIC) her claim for
deposit insurance and submitted the requirements. On August
22, 2014, petitioner executed an Affidavit 2 in support of her
claim. She attested therein that she verbally informed the
cashier/teller, a certain Eliza Dela Peña, that the money
deposited in trust for her by Teresita is payment for the loan that
she extended. Petitioner also categorically stated that she is the
exclusive owner of Special Savings Account No. 001 03-00904-1
where the amount of five hundred thousand pesos (P500,000.00)
was deposited.

In a Letter dated August 27, 2014, 3 PDIC through its Claims

Deposit Department, denied petitioner's claim for payment of
deposit insurance on the ground that there were no bank
records/documents to support consideration for the transfer of
funds to the subject deposit account, thus, beneficial ownership
thereof is retained by Teresita. Thereafter, petitioner, on
October 30, 2014, filed her Request for Reconsideration (RFR) 4
2
Annex “B”.
3
Annex “C”.
4
Annex “D”.
Petition for Certiorari on Certiorari
Servo vs. PDIC

which was also denied by PDIC on the ground that the former
failed to establish that “the break-up and transfer of legitimate
deposit to the transferee is for a valid consideration,” considering
that she is not a relative within the second degree of
consanguinity or affinity of Teresita.

On July 18, 2016, petitioner visited the office of PDIC to

follow-up her RFR. In response, PDIC gave her a copy of the
letter dated July 16, 20155 addressed to petitioner containing the
ground for the denial of the RFR.

On August 19, 2016, petitioner filed a Petition for Certiorari 6

with the RTC, Makati City. The case was docketed as SCA No.
16-01620-SC and was raffled before Branch 142 thereof.

Petitioner claimed that she submitted the necessary

documentary requirements in support of her claim for the deposit
insurance. Notwithstanding such, PDIC denied her claim for
payment of insurance as well as her request for consideration.
She further claimed that the denial of her RFR was arbitrary
without considering the available remedies such as requiring to
submit additional documents that would clearly support her claim
and/or call for a clarificatory meeting, as provided in Section 4(b)
and 4(c) of Regulatory Issuance No. 2011-03, in order to make
an equitable determination on the validity and/or propriety of her
claim.

On the other hand, PDIC contended that the RTC has no

jurisdiction to pass upon the subject matter of the petition
considering that PDIC is a co-equal body performing quasi-
judicial function in determining and passing upon the validity of
the claims for deposit insurance. It further contended that there
is no grave abuse of discretion amounting to lack or in excess of
jurisdiction. PDIC conscientiously arrived at its decision after
meticulous tracing, evaluation and analysis of available bank
documents and that despite the fact that petitioner was given the

5
Annex “E”.
6
Annex “F”.
Petition for Certiorari on Certiorari
Servo vs. PDIC

opportunity to prove that there was a valid transfer that would

justify the deposit to the subject account, she failed to do so,
resulting to the denial of her RFR.

On July 27, 2017, the trial court rendered the a Decision, 7

dismissing the case, without prejudice, on the ground of lack of
jurisdiction.

On September 7, 2017, petitioner filed a Petition for

Certiorari8 with the Court of Appeals.

On September 22, 2017, the Court of Appeals issued the

assailed Resolution, dismissing the case for lack of jurisdiction.

Hence, the present recourse.

GROUND IN SUPPORT OF THE PETITION

THE COURT OF APPEALS SERIOUSLY ERRED IN

DISMISSING OUTRIGHT THE PETITION FOR
CERTIORARI WITHOUT CONSIDERING THE FACT THAT
THE RTC'S DISMISSAL OF THE CASE WAS “WITHOUT
PREJUDICE” WHICH PROMPTED PETITIONER TO HAVE
AN ALTERNATIVE PRAYER TO DECIDE THE CASE ON
THE MERITS.

ARGUMENTS AND DISCUSSION

In the assailed Resolution, the Court of Appeals made the

sweeping observations:

“In dismissing petitioner's action without prejudice,

public respondent held that the RTC has no jurisdiction to
entertain Rule 65 petitions pertaining to acts and omissions of
quasi-judicial agencies as these are cognizable only by this Court.
7
Annex “G”.
8
Annex “H”.
Petition for Certiorari on Certiorari
Servo vs. PDIC

Said ruling was made taking into account the pertinent provisions
of B.P. 129 and Republic Act (R.A.) No. 3591, as amended by
R.A. 10846, which is the charter of private respondent PDIC.

Ascribing, grave abuse of discretion on the part of public

respondent, petitioner alleges that the dismissal is not proper
because PDIC is a government instrumentality that operates
under the Department of Finance. She insists that the mere fact
that PDIC performs quasi-judicial functions does not make it co-
equal to the RTC.

At this point, this Court sees the need to address a

procedural infirmity.

The issue brought before us involves the jurisdiction of the

RTC over the subject matter of the case.

It is settled that a court's jurisdiction over the subject

matter of the action is conferred only by the Constitution or by
the statute. Stated otherwise, the jurisdiction of a court over the
subject matter of the case is a matter of law. Consequently, an
issue dealing with the jurisdiction of a court over the subject
matter of a case is a pure question of law, hence, this action
should have been directly taken to the Supreme Court.”

While the main issue of the petition filed with the Court of
Appeals was admittedly a legal one, i.e., whether jurisdiction
over the subject matter is vested with the RTCs or with the Court
of Appeals, nevertheless, petitioner opted to seek the resolution
of her case on the merits in the event that the Court of Appeals
rules that it has jurisdiction over the case considering that the
dismissal of her case was without prejudice to its refiling to the
Court of Appeals. To wit:

“At any rate, even assuming that the Honorable Court

rules that the RTC has no jurisdiction over the case, still, in the
interest of substantial justice and equity, the Honorable Court
may validly treat the instant petition as a petition for certiorari to
the PDIC's denial of petitioner's claim in view of the clear grave
abuse of discretion committed by the PDIC in such denial.
Petition for Certiorari on Certiorari
Servo vs. PDIC

In the PDIC brochure entitled “Understanding Deposit

Insurance,”9 the PDIC never divulged to the public the
requirement that in “ITF” accounts, there should be evidence of
a valid consideration in case the beneficiary is not a relative by
consaguinity or by affinity.

In this case, although petitioner was able to explain that

the amount of deposit was derived through payment of the loan
of Teresita Gutierrez, the PDIC still refused to honor her claim.
Clearly, the PDIC gravely abused its discretion in denying
petitioner's claim.

In sum, apropos is the ruling in PDIC vs. Court of

Appeals:10

“Mere conjectures that MBC had actual

knowledge of its impending closure do not
suffice. The MB resolution could not thus have
nullified respondents transactions which occurred
prior to May 26, 1987.
That no actual money in bills and/or coins was
handed by respondents to MBC does not mean that
the transactions on the new GTDs did not involve
money and that there was no consideration
therefor. For the outstanding balance of
respondents 71 GTDs in MBC prior to May 26,
1987 in the amount of P1,115,889.15 as earlier
mentioned was re-deposited by respondents under
28 new GTDs. Admittedly, MBC had P2,841,711.90
cash on hand more than double the outstanding
balance of respondents 71 GTDs at the start of the
banking day on May 25, 1987. Since respondent
Jose Abad was at MBC soon after it opened at 9:00
a.m. of that day, petitioner should not presume
that MBC had no cash to cover the new GTDs
of respondents and conclude that there was no
consideration for said GTDs.
Petitioner having failed to overcome the
presumption that the ordinary course of
business was followed,this Court finds that the

9
Annex “I”.
10
G.R. No. 126911, April 30, 2003.
Petition for Certiorari on Certiorari
Servo vs. PDIC

28 new GTDs were deposited in the usual

course of business of MBC.”

Clearly, the entirety of the petition involved a mixed

question of fact and law. A petition assailing the decision
involving both questions of fact and law must first be brought
before the Court of Appeals.11

On this point, the ruling in Latorre vs. Latorre12 is

instructive:

“In her Reply to respondents Comment, petitioner

prayed that this Court decide the case on the merits. To do
so, however, would require the examination by this Court of the
probative value of the evidence presented, taking into account
the fact that the RTC failed to adjudicate this controversy
on the merits. This, unfortunately, we cannot do. It thus
becomes exceedingly clear that the filing of the case directly
with this Court ran afoul of the doctrine of hierarchy of
courts. Pursuant to this doctrine, direct resort from the lower
courts to the Supreme Court will not be entertained unless the
appropriate remedy sought cannot be obtained in the lower
tribunals. This Court is a court of last resort, and must so remain
if it is to satisfactorily perform the functions assigned to it by the
Constitution and by immemorial tradition.”

Applying the above-pronouncement to the instant case,

petitioner properly filed a petition for certiorari with the Court of
Appeals pursuant to Section 1(h), Rule 41 of the Rules of Court
which mandates that no appeal may be taken from an order
dismissing an action without prejudice and in anticipation that
her right to re-file the case with the Court of Appeals may be lost
in the event that the RTC's lack of jurisdiction is affirmed. A
petition assailing the decision involving both questions of fact and
law must first be brought before the Court of Appeals.

There is a crying need to unclog court dockets, on the one

hand, there is, on the other, a greater demand for resolving
11
Far Eastern Surety & Insurance Co. Inc., vs. People, G.R. No. 170618, November
20, 2013, 710 SCRA 358.
12
G.R. No. 183926, March 29, 2010, 617 SCRA 88.
Petition for Certiorari on Certiorari
Servo vs. PDIC

genuine disputes fairly and equitably,13 for it is far better to

dispose of a case on the merit which is a primordial end, rather
than on a technicality that may result in injustice. 14

In Municipality of Pateros vs. Court of Appeals, 15 the

Municipality of Pateros filed an appeal under Rule 42 before the
Court of Appeals, which the Court of Appeals denied outright for
raising pure questions of law. The Supreme Court agreed that the
Municipality of Pateros "committed a procedural infraction" and
should have directly filed a petition for review on certiorari before
the Supreme Court. Nevertheless, "in the interest of justice and
in order to write finis to [the] controversy," the Supreme Court
"opt[ed] to relax the rules"and proceeded to decide the case.
Thus:

“While it is true that rules of procedure are intended to

promote rather than frustrate the ends of justice, and while the
swift unclogging of the dockets of the courts is a laudable
objective, it nevertheless must not be met at the expense of
substantial justice.

The Supreme Court has allowed some meritorious cases to

proceed despite inherent procedural defects and lapses. This is
in keeping with the principle that rules of procedure are mere
tools designed to facilitate the attainment of justice, and that
strict and rigid application of rules which should result in
technicalities that tend to frustrate rather than promote
substantial justice must always be avoided. It is a far better and
more prudent cause of action for the court to excuse a technical
lapse and afford the parties a review of the case to attain the
ends of justice, rather than dispose of the case on technicality
and cause grave injustice to the parties, giving a false
impression of speedy disposal of cases while actually resulting in
more delay, if not a miscarriage of justice.

In those rare cases to which we did not stringently apply

the procedural rules, there always existed a clear need to
prevent the commission of a grave injustice. Our judicial system
and the courts have always tried to maintain a healthy

13
Santos vs. Court of Appeals, 323 Phil. 762, 770 (1996).
14
Heirs of Reinoso, Sr. vs. Court of Appeals, G.R. No. 116121, July 18, 2011.
15
G.R. No. 157714, June 16, 2009, 589 SCRA 130.
Petition for Certiorari on Certiorari
Servo vs. PDIC

balance between the strict enforcement of procedural

laws and the guarantee that every litigant is given the
full opportunity for a just and proper disposition of his
cause.

The emerging trend in the rulings of this Court is to afford

every party litigant the amplest opportunity for the proper and
just determination of his cause, free from the constraints of
technicalities. Time and again, we have consistently held that
rules must not be applied so rigidly as to override substantial
justice.”

It must be emphasized that at the time of the filing of the

petition for certiorari with the Court of Appeals, there is no
jurisprudence yet which could settle the issue as to where
petitions for certiorari from the PDIC's denial of the claims for
insured deposits should be filed. Hence, with more reason that
this Honorable Court must rule on the issue of jurisdiction.

Petitioner hereby adopts and repleads her arguments and

discussion in the petition for certiorari filed with the Court of
Appeals. Thus:

PDIC is not co-equal with the RTCs

The PDIC was created by R.A. No. 3591 on June 22,

1963 as an insurer of deposits in all banks entitled to the
benefits of insurance under the PDIC Charter to promote and
safeguard the interests of the depositing public by way of
providing permanent and continuing insurance coverage of all
insured deposits. It is a government instrumentality that
operates under the Department of Finance. Its primary
purpose is to act as deposit insurer, as a co-regulator of banks,
and as receiver and liquidator of closed banks.16

Considering that the rulings of the Department of Finance

are appealable to the Court of Tax Appeals, the latter having the
same rank with the Court of Appeals as collegiate court, it
16
PDIC vs. Countryside Rural Bank, Inc., G.R. No. 176438, January 24, 2011.
Petition for Certiorari on Certiorari
Servo vs. PDIC

cannot be said that the rulings of the PDIC, which is under the
Department of Finance, are also appealable only with the Court
of Appeals.

In ruling that the PDIC is co-equal with the RTCs, public

respondent Judge ratiocinated in this wise:

“The rule is that where legislation provides for the filing of

an appropriate petition for certiorari on acts or omissions of
certain administrative bodies to the Court of Appeals, it means
that such bodies are co-equal with the Regional Trial Court
(RTC), in terms of rank and stature, and logically, beyond the
control of the latter. “

Petitioner begs to disagree.

It must be noted that PDIC is not among those agencies

and quasi-judicial bodies enumerated under Sec. 1, Rule 43 of
the Rules of Court whose decisions and rulings are appealable
through a petition for review to the Court of Appeals. Hence,
there is no basis to conclude that PDIC is co-equal with the
RTCs.

Moreover, the mere fact that PDIC performs quasi-judicial

functions does not make it co-equal with the RTCs. On this
point, the ruling in LLDA vs. Court of Appeals17 is appropriate:

“there is no question that the Authority has express

powers as a regulatory and quasi-judicial body in respect to
pollution cases with authority to issue a 'cease and desist order'
and on matters affecting the construction of illegal fishpens,
fishcages and other aqua-culture structures in Laguna de Bay.
The Authority's pretense, however, that it is co-equal to the
Regional Trial Courts such that all actions against it may only be
instituted before the Court of Appeals cannot be sustained. On
actions necessitating the resolution of legal questions
affecting the powers of the Authority as provided for in its
charter, the Regional Trial Courts have jurisdiction.”

17
G.R. Nos. 120865-71 December 7, 1995.
Petition for Certiorari on Certiorari
Servo vs. PDIC

Clearly, PDIC's claim that it is a co-equal body with the

regional trial courts is absurd. It should be of judicial notice that
the PDIC has been involved in numerous RTC cases in its
capacity as a Liquidator and in those suits, the PDIC never raised
its claim that it is a co-equal body with the trial court and that
the latter has no authority and power to control it (PDIC). In
one case, PDIC itself even invoked the jurisdiction of the RTC in
order to determine the validity of the questionable insured
deposits. Thus:

“Prior to May 22, 1997, respondents had, individually or

jointly with each other, 71 certificates of time deposits
denominated as Golden Time Deposits (GTD) with an aggregate
face value of P1,115,889.96.

On May 22, 1987, a Friday, the Monetary Board (MB) of

the Central Bank of the Philippines, now Bangko Sentral ng
Pilipinas, issued Resolution 505 prohibiting MBC to do business in
the Philippines, and placing its assets and affairs under
receivership. The Resolution, however, was not served on MBC
until Tuesday the following week, or on May 26, 1987, when the
designated Receiver took over.

On May 25, 1987, the next banking day following the

issuance of the MB Resolution, respondent Jose Abad was at the
MBC at 9:00 a.m. for the purpose of pre-terminating the 71
aforementioned GTDs and re-depositing the fund represented
thereby into 28 new GTDs in denominations of P40,000.00 or
less under the names of herein respondents individually or
jointly with each other. Of the 28 new GTDs, Jose Abad pre-
terminated 8 and withdrew the value thereof in the total amount
of P320,000.00.

Respondents thereafter filed their claims with the PDIC for

the payment of the remaining 20 insured GTDs.

On February 11, 1988, PDIC paid respondents the value of

3 claims in the total amount of P120,000.00. PDIC, however,
withheld payment of the 17 remaining claims after Washington
Solidum, Deputy Receiver of MBC-Iloilo, submitted a report to
the PDIC that there was massive conversion and substitution of
Petition for Certiorari on Certiorari
Servo vs. PDIC

trust and deposit accounts on May 25, 1987 at MBC-Iloilo. The

pertinent portions of the report stated:

xxx

On May 25, 1987 (Monday) or a day prior to the official

announcement and take-over by CB of the assets and liabilities
of The Manila Banking Corporation, the Iloilo Branch was found
to have recorded an unusually heavy movements in terms of
volume and amount for all types of deposits and trust accounts.
It appears that the impending receivership of TMBC was
somehow already known to many depositors on account of the
massive withdrawals paid on this day which practically wiped out
the branch's entire cash position. . . .

xxx

. . . The intention was to maximize the availment of PDIC

coverage limited to P40,000 by spreading out big accounts to as
many certificates under various nominees. . . .

xxx

Because of the report, PDIC entertained serious

reservation in recognizing respondents GTDs as deposit
liabilities of MBC-Iloilo. Thus, on August 30, 1991, it filed
a petition for declaratory relief against respondents with
the Regional Trial Court (RTC) of Iloilo City, for a judicial
declaration determination of the insurability of
respondents GTDs at MBC-Iloilo.”18

The amendments in the PDIC

Charter should be given
prospective application

It cannot be said that the remedy of petitioner was to file a

petition for certiorari with the Court of Appeals pursuant to the
Amended PDIC Charter although the denial of the claim for the
insured deposits was made prior to the amendments in the
original PDIC Charter.

18
PDIC vs. Court of Appeals, G.R. No. 126911, April 30, 2003.
Petition for Certiorari on Certiorari
Servo vs. PDIC

The RFR was denied per PDIC Letter dated July 16, 2015,
which made reference to Regulatory Issuance No. 2011-03.

The PDIC Charter was amended on July 27, 2015 per RA

10846.

On this point, the pronouncement in Sps. Tirona vs. Hon.

Alejo is instructive”
19

“At the outset, we must point out that petitioners' reliance

upon Republic Act No. 7881 is off tangent. It is not disputed that
at the time of the filing of Civil Cases Nos. 6632 and 6633, an
agrarian relation's dispute was pending before the DARAB. The
records show that private respondents as the complainants in
Case No. IV-MM-0099-95R, were asserting tenancy rights,
including the right to possession of the disputed fishponds or
parts thereof, under Republic Act Nos. 384418 and 1199. Private
respondents were thus claiming vested substantive rights, dating
back to 1975 in the case of respondent Ignacio and 1979 in the
case of respondent Nuñez, under substantive laws. A substantive
law is a law, which creates, defines, or regulates rights
concerning life, liberty, or property, or the powers of agencies or
instrumentalities for the administration of public affairs. Republic
Act No. 7881, in exempting prawn and fishponds from the
coverage of the Comprehensive Agrarian Reform Law of 1988, is
a substantive law. By its very nature and essence, substantive
law operates prospectively and may not be construed
retroactively without affecting previous or past rights. Hence, in
view of the absence of a contrary intent in its provisions, Republic
Act No. 7881 should be given a prospective operation and may
not affect rights claimed under previous agrarian legislation.”

In this case, the RFR was denied pursuant to the original

PDIC Charter or prior to its amendment. Hence, petitioner
correctly availed of the remedy provided for under the original
PDIC Charter, particularly Section 7, thereof, thus:

“Section 7. Remedy in Case of Denial of Request for

Reconsideration.
19
G.R. No. 129313, October 10, 2001.
Petition for Certiorari on Certiorari
Servo vs. PDIC

A depositor whose request for reconsideration is denied by

the PDIC with finality shall have thirty (30) days from receipt of
the notice denying the request for reconsideration within which to
file a petition for certiorari with the court pursuant to Sec. 4(g)
of the PDIC Charter.”

The regional trial court, formerly the court of first instance,

is a court of general jurisdiction. All cases, the jurisdiction over
which is not specifically provided for by law to be within the
jurisdiction of any other court, fall under the jurisdiction of the
regional trial court.20

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed of this Honorable Court that the Resolution dated
September 22, 2017 of the Court of Appeals be REVERSED AND
SET ASIDE and that this case be REMANDED to the proper
court with the corresponding DIRECTIVE to RESOLVE WITH
DISPATCH the merits of petitioner's petition for certiorari.

Other just and equitable reliefs under the premises are

likewise prayed for.

MOST RESPECTFULLY SUBMITTED.

Parañaque City for the City of Manila,

October 13, 2017.

DIVINA PAZ S. CACAPIT-SACRAMENTO

Counsel for Petitioner
Attorney's Roll No. 44908
IBP Lifetime Member No. 03651/PPLM
PTR No. 0870776/05 Jan17/P'que City
MCLE Compliance No. V-0021228/14Apr'16

20
Durisol Phils. vs. Court of Appeals, G.R. No. 121106, February 20, 2002.
Petition for Certiorari on Certiorari
Servo vs. PDIC

SACRAMENTO LAW OFFICE

U29 Solid Arcade, Presidents Avenue,
Bgy BF Homes, Parañaque City 1700
Metro Manila *Tel. No. 8250127

Copy furnished:

(VIA PERSONAL SERVICE)

COURT OF APPEALS
Ma. Orosa St., Ermita, Manila

(VIA REGISTERED MAIL)*

OFFICE OF THE GOVERNMENT
CORPORATE COUNSEL (Counsel for PDIC)
3rd Flr., MWSS Administration Bldg.,
Katipunan Avenue, QUEZON CITY

OFFICE OF THE GENERAL COUNSEL

PHILIPINE DEPOSIT INSURANCE CORPORATION
6782 Ayala Avenue corner Rufino Street,
SSS Building, MAKATI CITY

*Due to distance and lack of personnel to effect personal service,

service of the foregoing pleading was made via registered mail.