G.R. No. 192048 - Anama vs. Citibank, N.A.

Title: Anama vs. Citibank, N.A.

Case: G.R. No. 192048

Decision Date: Dec 13, 2017

Anama sought to revive a 1982 CA judgment against Citibank, but the Supreme Court ruled that the RTC, not the CA, has jurisdiction over revival actions, denying his petition.

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Case Digest (G.R. No. 192048)
Legal Reasoning Model

Facts:

Background of the Loan and Security

In 1972, petitioner Douglas F. Anama obtained a loan from respondent Citibank (formerly First National City Bank of New York).

In connection with the loan, Anama executed a promissory note for P418,000.00.

To secure the obligation, Anama executed a chattel mortgage in favor of Citibank over industrial machineries and equipment located at his property along E. de los Santos Avenue, Quezon City.

Default and Initial Litigation

Anama failed to pay the monthly installments beginning January 1974.

On November 13, 1974, Citibank filed a complaint for sum of money and replevin (Civil Case No. 95991) in the Court of First Instance of Manila (now RTC, Branch 11).

Anama filed an answer with a counterclaim, alleging that:

His non-payment was due to Citibank’s refusal to accept his checks.

The chattel mortgage was defective and void.

Seizure Proceedings by the Trial Court

On December 2, 1974, after proof of Anama’s default, the RTC issued an Order of Replevin over the mortgaged properties.

On January 29, 1977, Citibank sought an alias writ of seizure alleging that the properties, taken by the Sheriff, had not been delivered to it.

The RTC granted the motion on February 28, 1977, and the Ex-Officio Sheriff of Quezon City issued receipts for the seized items on March 17–19, 1977.

Anama’s motion for reconsideration was denied by the RTC on March 18, 1977.

Intervention of the Court of Appeals (CA)

On March 21, 1977, Anama filed a petition for certiorari and prohibition with a writ of preliminary injunction before the CA (docketed as CAA G.R. SP No. 06499).

He challenged the RTC resolutions, arguing they were issued in excess of jurisdiction and with grave abuse of discretion due to the lack of evidence proving Citibank’s right over the seized properties.

On July 30, 1982, the CA granted his petition:

The CA nullified the RTC’s orders of seizure ab initio.

It ordered the return of the machineries and equipment to Anama’s premises and directed the repair of damages incurred during seizure.

The writ of preliminary injunction was made permanent.

Further Litigations and Reconstruction of Records

Citibank filed a petition for review on certiorari with the Supreme Court on August 25, 1982, challenging the CA’s ruling.

On March 17, 1999, the Supreme Court dismissed Citibank’s petition, affirming the CA’s July 30, 1982 Decision.

An entry of judgment was issued on April 12, 1999.

On November 19, 1981, a fire at Manila City Hall destroyed records, including those of Civil Case No. 95991.

Anama secured the reconstruction of records through a petition to the RTC, which was granted on May 3, 1982.

Subsequently, on December 2, 1982, pending incidents in Civil Case No. 95991 were suspended pending resolution of G.R. No. 61508.

Petition for Revival of Judgment and Subsequent Proceedings

On March 12, 2009, Anama filed a petition for revival of judgment with the CA (docketed as CA-G.R. SP No. 107748).

He sought to revive the CA’s July 30, 1982 Decision.

He argued that Citibank’s failure to initiate proceedings for reconstitution of the RTC records amounted to abandonment of its cause of action against him.

Anama also requested the remand of Civil Case No. 95991 for further proceedings, including his counterclaims.

Citibank responded that:

Revival of judgment is within the exclusive original jurisdiction of the RTC.

The petition was time-barred by laches, as Anama had delayed nearly 10 years.

Citibank did not abandon its claim in Civil Case No. 95991.

On November 19, 2009, the CA denied the petition for revival on the ground of lack of jurisdiction.

Anama’s motion for reconsideration was filed but was denied on April 20, 2010.

Further pleadings followed:

On June 10, 2010, Anama filed a petition before the Supreme Court, contending that revival actions should be filed in the court that originally rendered the judgment (i.e., the CA).

Citibank maintained that revival actions fall under the exclusive jurisdiction of the RTC.

Subsequent comments and manifestations were filed by both parties between 2016 and 2017.

Issue:

Jurisdictional Issue

Whether the petition for revival of judgment should be filed with the Court of Appeals or with the Regional Trial Court.

Whether the CA possesses jurisdiction to hear an action for revival of judgment when the underlying matter involves non-pecuniary issues and is not within its exclusive appellate mandate.

Procedural and Laches Considerations

Whether the delay (laches) in filing the petition for revival of judgment by Anama renders the petition barred.

Whether Citibank’s alleged failure to institute proceedings for the reconstitution of records constitutes abandonment of its cause of action.

Nature of the Revival Action

Whether a revival action is an independent new action with its own cause of action distinct from the original judgment.

How the distinct nature of revival actions affects the appropriate venue and jurisdiction for such petitions.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Doctrine:

(Subscriber-Only)

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