The Supreme Court held that the Bangko Sentral ng Pilipinas (BSP) can engage private counsel authorized by the Monetary Board to represent it in legal proceedings. This ruling affirms the RTC’s jurisdiction over a case filed by the BSP, emphasizing that the inclusion of a tax declaration as an annex to the complaint is sufficient to establish the assessed value of the property in question. This decision clarifies the extent of BSP’s autonomy in legal representation and reinforces the principle that attachments to a complaint are integral to determining jurisdictional facts.

Title to Land and Legal Representation: Unraveling BSP’s Day in Court

This case arose from a complaint filed by the Bangko Sentral ng Pilipinas (BSP) against several individuals, including Feliciano P. Legaspi, the then-incumbent Mayor of Norzagaray, Bulacan, concerning the annulment of title, revocation of certificate, and damages related to a property dispute. The central legal questions revolved around two critical aspects: whether the Regional Trial Court (RTC) had jurisdiction over the subject matter of the complaint, and whether the BSP was authorized to engage private counsel to represent it in the litigation. These issues stemmed from Legaspi’s motion to dismiss, arguing that the RTC lacked jurisdiction and that the BSP’s representation by private counsel was improper.

The Court addressed the issue of jurisdiction by referring to Batas Pambansa Bilang 129, as amended by Republic Act No. 7691, which stipulates that RTCs have exclusive original jurisdiction over civil actions involving title to or possession of real property, provided that the assessed value of the property exceeds Twenty Thousand Pesos (P20,000.00). While the complaint itself did not explicitly state the assessed value, the BSP argued that the attached Tax Declaration (Annex “N”) indicated an assessed value of P215,320.00, thereby satisfying the jurisdictional requirement.

The Supreme Court emphasized the importance of considering annexes to a complaint, stating that they are deemed part of, and should be considered together with, the complaint. This principle is rooted in established jurisprudence, as the Court noted in Fluor Daniel, Inc.-Philippines v. E.B. Villarosa and Partners Co., Ltd.:

We have ruled that a complaint should not be dismissed for insufficiency of cause of action if it appears clearly from the complaint and its attachments that the plaintiff is entitled to relief. The converse is also true. The complaint may be dismissed for lack of cause of action if it is obvious from the complaint and its annexes that the plaintiff is not entitled to any relief.

Building on this principle, the Court held that the Tax Declaration attached to the BSP’s complaint was an integral part of the pleading and should be considered in determining whether the RTC had jurisdiction. This approach contrasts with the CA’s reliance on Quinagoran v. Court of Appeals, where the assessed value of the land was not on record before the trial court. In the present case, the Tax Declaration, being a public record, was already considered on file with the court.

The Court further noted that the area of the subject land was substantial—four million eight hundred thirty-eight thousand seven hundred and thirty-six (4,838,736) square meters. Given the size of the property, it would be illogical for its assessed value to be less than P20,000.00. This observation reinforced the RTC’s decision to take judicial notice of the assessed value, as it is a well-established principle that a court may take judicial notice of its own acts and records in the same case, as well as public records on file in the same court.

The second key issue concerned the BSP’s legal representation. The Court of Appeals (CA) had ruled that the BSP, being a government-owned and controlled corporation, should have been represented by the Office of the Solicitor General (OSG) or the Office of the Government Corporate Counsel (OGCC), rather than a private law firm. However, the Supreme Court disagreed with this assessment.

According to Republic Act No. 7653, or the New Central Bank Act, the BSP Governor is authorized to represent the Bangko Sentral, either personally or through counsel, including private counsel, as may be authorized by the Monetary Board, in any legal proceedings, action, or specialized legal studies. Section 18(c) of R.A. No. 7653 explicitly states:

represent the Bangko Sentral, either personally or through counsel, as may be authorized by the Monetary Board, in any legal proceedings, action or specialized legal studies.

Moreover, the BSP Governor may delegate this power to represent the BSP to other officers upon his own responsibility. The RTC had found that the BSP had adequately justified its representation by private counsel, based on Monetary Board Resolution No. 865, dated June 17, 2004, and Monetary Board Resolution No. 900, adopted on July 18, 2008. These resolutions authorized the Director of the Asset Management Department (AMD) to sign documents related to the acquired assets and approved the engagement of Ongkiko Kalaw Manhit and Acorda Law Offices (OKMA Law) to act as counsel for the BSP.

In summary, the Court underscored that the filing of the suit and the engagement of the services of counsel were duly authorized by the BSP. The Court also noted the absence of any disavowal from the Governor, General Counsel, or Monetary Board regarding the authority given for filing the suit and engaging the counsel’s services. Therefore, in cases involving the BSP, the Monetary Board may authorize the BSP Governor to represent it personally or through a counsel, even a private counsel, and this authority can be delegated to any of its officers.

FAQs

What was the key issue in this case?	The central issues were whether the RTC had jurisdiction over the property dispute and whether the BSP was authorized to engage private counsel for the litigation.
How did the Court determine if the RTC had jurisdiction?	The Court considered the Tax Declaration attached to the complaint, which showed the assessed value of the property exceeded P20,000.00, thus satisfying the jurisdictional requirement.
Can annexes to a complaint be considered in determining jurisdiction?	Yes, the Supreme Court affirmed that annexes to a complaint are deemed part of it and should be considered together with the complaint in determining jurisdiction.
What law governs the BSP’s authority to engage counsel?	Republic Act No. 7653, or the New Central Bank Act, authorizes the BSP Governor to represent the BSP through counsel, including private counsel, as authorized by the Monetary Board.
Can the BSP Governor delegate the power to represent the BSP?	Yes, the BSP Governor may delegate the power to represent the BSP to other officers, as provided in the New Central Bank Act.
What was the CA’s ruling on the BSP’s legal representation?	The CA ruled that the BSP should have been represented by the OSG or the OGCC, not a private law firm, which the Supreme Court reversed.
What is the significance of Monetary Board Resolutions in this case?	Monetary Board Resolutions authorized the Director of the AMD to sign documents and approved the engagement of OKMA Law to act as counsel for the BSP, justifying the BSP’s legal representation.
Was there any opposition from BSP leadership regarding the engagement of private counsel?	No, the Court noted that neither the Governor, General Counsel, nor the Monetary Board disavowed the authority given for filing the suit and engaging the counsel’s services.

This ruling reinforces the BSP’s autonomy in engaging private counsel and reaffirms the principle that attachments to a complaint are integral to determining jurisdictional facts. The decision ensures that the BSP can effectively pursue its legal interests through authorized representation, ultimately upholding its mandate as the central monetary authority of the Philippines.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: BANGKO SENTRAL NG PILIPINAS vs. FELICIANO P. LEGASPI, G.R. No. 205966, March 02, 2016