Title
Carandang vs. Court of Appeals
Case
G.R. No. L-44932
Decision Date
Apr 15, 1988
Carandang v. Court of Appeals is a case involving the nullification of a promissory note and mortgage deed, which were found to be forgeries, leading to a jurisdictional battle and the declaration of the documents as null and void.
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Case Digest (G.R. No. L-44932)

Facts:

  • Petitioners Jose Carandang and Benita Carandang filed a complaint for the cancellation and nullification of a promissory note and mortgage deed.
  • The complaint was filed with the Court of First Instance (CFI) of Laguna.
  • The petitioners claimed that the documents were forgeries.
  • The Rural Bank of Lucena, Inc., one of the respondents, argued that the CFI of Laguna did not have jurisdiction over the case due to the ongoing liquidation proceedings of the bank in the Court of First Instance of Manila.

Issue:

  • (Unlock)

Ruling:

  • The CFI of Laguna has jurisdiction over the case for the cancellation and nullification of the promissory note and mortgage deed.
  • The documents were found to be forgeries and were declared null and void.
  • The receivers...(Unlock)

Ratio:

  • The action for nullification of the mortgage documents is a real action because it affects the title to the property.
  • Therefore, the action should be brought before the court having jurisdiction over the territory in which the subject property lies, which is the CFI of Laguna.
  • The liquidation court, which is a court of limited jurisdiction, cannot pass upon the validity of contracts such as the mortgage deed in question.
  • This matter should be liti...continue reading

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