Suspension of payments for money claims vs. corporations
The relevant law dealing with the suspension of payments for money claims against corporations under rehabilitation is Presidential Decree (PD) No. 902-A, as amended.The term claim under said law refers to debts or demands of pecuniary nature. It is the assertion of rights for the payment of money. The raison d' tre behind the suspension of claims pending rehabilitation was explained in the case of BF Homes, Inc. v. CA:
In Philippine Air Lines [(PAL)], Incorporated v. Zamora, we said that all actions for claims against a corporation pending before any court, tribunal or board shall ipso jure be suspended in whatever stage such actions may be found upon the appointment by the SEC of a management committee or a rehabilitation receiver.
...the reason for suspending actions for claims against the corporation should not be difficult to discover. It is not really to enable the management committee or the rehabilitation receiver to substitute the [corporation] in any pending action against it before any court, tribunal, board or body. Obviously, the real justification is to enable the management committee or the rehabilitation receiver to effectively exercise its/his powers free from any judicial or extra-judicial interference that might unduly hinder or prevent the rescue of the debtor [corporation]. To allow such other action to continue would only add to the burden of the management committee or rehabilitation receiver, whose time, effort and resources would be wasted in defending claims against the corporation instead of being directed toward its restructuring and rehabilitation.
In Philippine Air Lines [(PAL)], Incorporated v. Zamora, we said that all actions for claims against a corporation pending before any court, tribunal or board shall ipso jure be suspended in whatever stage such actions may be found upon the appointment by the SEC of a management committee or a rehabilitation receiver.
However, we would still find no cogent reason to reverse our August 17, 2005 resolution denying petitioner's appeal even if the proceedings here were to be suspended in the meantime. And such suspension would not at all affect our position that the MR should be denied as well. (G.R. No. 168522; December 19, 2007)