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

On November 10, 1972, petitioner Douglas F. Anama executed a promissory note in favor of First National City Bank of New York (now Citibank, N.A.) for ₱418,000.00.
To secure payment, Anama granted Citibank a chattel mortgage over various industrial machineries and equipment located at his property in Quezon City.

Beginning January 1974, Anama defaulted on monthly installments. On November 13, 1974, Citibank filed a complaint for sum of money and replevin in the Court of First Instance of Manila (Civil Case No. 95991). Anama counterclaimed, alleging Citibank’s refusal to accept checks and asserting defects in the mortgage.
The RTC issued an order of replevin (December 2, 1974) and, upon Citibank’s motion, an alias writ of seizure (February 28, 1977), resulting in the Sheriff’s taking possession in March 1977. Anama’s motion for reconsideration was denied (March 18, 1977), prompting his petition for certiorari and prohibition with the Court of Appeals (CA) on March 21, 1977.

On July 30, 1982, the CA granted certiorari, nullified the RTC’s seizure orders as void ab initio, and ordered the return and restoration of the machineries and equipment. Citibank’s subsequent petition for review to the Supreme Court was dismissed on March 17, 1999, with entry of judgment on April 12, 1999, affirming the CA decision.

On November 19, 1981, a fire destroyed the fourth floor of Manila City Hall, including RTC Branch 11’s records for Civil Case No. 95991. Anama filed a petition for reconstruction on February 10, 1982, which the RTC granted on May 3, 1982.
With the Supreme Court petition pending, the RTC suspended all proceedings in Civil Case No. 95991 by order dated December 2, 1982.

On March 12, 2009, Anama filed with the CA a petition to revive the CA’s July 30, 1982 decision, arguing Citibank’s inaction on reconstitution amounted to abandonment. Citibank opposed, contending revival actions fall within the RTC’s exclusive jurisdiction and that laches barred the petition.
The CA denied the petition for lack of jurisdiction on November 19, 2009, and denied reconsideration on April 20, 2010. Anama then filed a petition for certiorari before the Supreme Court on June 10, 2010. After submissions and supplemental memoranda, the Supreme Court rendered its decision on December 13, 2017.

Whether the Court of Appeals had jurisdiction to entertain an action for revival of judgment.
Whether Anama’s petition for revival of judgment is barred by laches.
Whether Citibank abandoned its cause of action by failing to initiate reconstruction of the RTC records.