Case Digest (G.R. No. 140420) Core Legal Reasoning Model
Facts:
In Sergio Amonoy v. Spouses Jose Gutierrez and Angela Fornilda (G.R. No. 140420, February 15, 2001), Sergio Amonoy, an attorney, acted as counsel for heirs in the settlement of the estate of the late Julio Cantolos before the Court of First Instance (CFI) of Pasig, Rizal. On January 12, 1965, the partition plan adjudicated two parcels to Asuncion Pasamba and Alfonso Fornilda, who secured Amonoy’s P27,600 attorney’s fees by mortgaging these lots. After the estate was closed on August 6, 1969, both mortgagors died. When the heirs failed to pay, Amonoy foreclosed the mortgage in Civil Case No. 12726, securing a judgment on September 28, 1972. Public auctions held in February and March 1973, followed by a deficiency sale, resulted in Amonoy acquiring ownership of the lots, one of which bore the Gutierrez spouses’ house. On December 19, 1973, the heirs sued to annul the foreclosure, but both CFI and the Court of Appeals dismissed the case, and the Supreme Court on October 5, 1988, p
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Case Digest (G.R. No. 140420) Expanded Legal Reasoning Model
Facts:
- Settlement of Julio Cantolos’s Estate (1965–1969)
- Special Proceedings No. 3103, CFI Pasig: Six parcels in Tanay, Rizal partitioned; two lots adjudicated to Asuncion Pasamba and Alfonso Fornilda; attorney’s fees of P27,600 secured by real estate mortgage on those two lots.
- Estate closure and deaths: Taxes paid and estate closed August 6, 1969; Pasamba died February 24, 1969; Fornilda died July 2, 1969; Angela Gutierrez among his heirs.
- Foreclosure and Auction Sales (1970–1973)
- Foreclosure Case No. 12726 (January 21, 1970): Amonoy sued heirs for unpaid fees; September 28, 1972 judgment required payment of P27,600 (fees), P11,880 (harvest value), P9,645 (additional fees), failing which lots to be auctioned.
- Sales and confirmation: First auction held March 23, 1973; Amonoy highest bidder at P23,760; bid confirmed May 2, 1973; deficiency sale followed with Amonoy bidding P12,137.50; included lot with respondents’ house.
- Post-Sale Remedies and Demolition Orders (1973–1988)
- Annulment suit No. 18731 filed December 19, 1973; CFI dismissed November 7, 1977; CA affirmed July 22, 1981; CFI issued Writ of Possession July 25, 1985; notice to vacate August 26, 1985; demolition orders April 25 and May 6, 1986.
- Supreme Court intervention: G.R. No. L-72306 filed September 27, 1985; TRO granted June 2, 1986 (served June 4, 1986); October 5, 1988 SC Decision permanently enjoined demolition and ordered return of parcels unless conveyed to innocent third parties—yet respondents’ house had already been destroyed.
- Damages Suit and Appellate Proceedings (1989–2001)
- Complaint for damages filed December 15, 1989 before RTC Tanay, Rizal; RTC dismissed suit January 27, 1993.
- Court of Appeals (CA) in CA-GR CV No. 41451 set aside RTC decision April 21, 1999, awarding P250,000 actual damages; CA denied reconsideration October 19, 1999; petition for review under Rule 45 filed with the Supreme Court.
Issues:
- Whether the Court of Appeals correctly held petitioner Sergio Amonoy liable for damages to respondents spouses Gutierrez arising from the demolition of their house.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)