Advent Capital and Finance Corporation v.

Alcantara
G.R. No. 183050/ January 25, 2012

FACTS:

Advent Capital and Finance Corporation filed a petition for rehabilitation and the receiver
found out that the Alcantaras owed the corporation for trust fees it earned in managing the
latter’s several trust accounts. The receiver requested Belson Securities, Inc. to deliver cash
dividends that Belson held under the Alcantaras’ Trust Account. Alcanataras alleged that the
petitioner could not claim any right or interest in the dividends generated by their investments
since Advent Capital merely held these in trust for the Alcantaras and the rehabilitation court had
no jurisdiction over the subject dividends.

HELD: Whether or not the court has jurisdiction to hear and adjudicate the conflicting claims of
the parties over the dividends that Belson held in trust for their owners.

RULINGS:
Rehabilitation proceedings are summary and non-adversarial in nature, and do not contemplate
adjudication of claims that must be threshed out in ordinary court proceeds. Adversarial
proceedings similar to that in ordinary courts are inconsistent with the commercial nature of a
rehabilitation case, which must be resolved quickly and expeditiously for the sake of the
corporate debtor, its creditors and other interested parties.

In this case, Advent Capital claim against the Alcantaras was a claim for payment of the supposed
management fees which is a proper subject for an ordinary action for collection. Such money
claim cannot be enforced by simple filing of a motion in the rehabilitation case for delivery of
money belonging to the Alcantaras but in the possession of a third party.