Title
Cayaba vs. Court of Appeals
Case
G.R. No. 95918
Decision Date
Mar 5, 1993
Spouses mortgaged land to a bank, which foreclosed and sold it to Cayaba. Trial court nullified the mortgage and sale, allowing spouses to repurchase. Bank appealed; Cayaba’s rights, tied to the bank’s appeal, were upheld by the Supreme Court, halting execution pending appeal.
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Case Digest (G.R. No. 95918)

Facts:

  1. Mortgage and Foreclosure:

    • The respondents, Spouses Rodolfo and Rosario Rapadas, executed a Deed of Real Estate Mortgage over their parcel of land in Barrio Barretto, Olongapo City, in favor of the Rural Bank of Olongapo, Inc., for a loan of P15,000.00.
    • The property was not yet covered by any sales or free patent.
    • The bank extrajudicially foreclosed the property and became the highest bidder at P17,557.15, receiving a Certificate of Sale.
  2. Sale to Petitioner:

    • Petitioner Lucio Cayaba bought the property from the bank under a conditional sale on March 19, 1979.
    • Before the expiration of the one-year redemption period, the Rapadas spouses attempted to repurchase or redeem the property but were refused. They then filed a motion to consignate the amount in court.
  3. Trial Court Decision:

    • On June 15, 1988, the trial court declared the Real Estate Mortgage null and void.
    • The sale made by the bank to Cayaba was also declared null and void.
    • The court allowed the Rapadas spouses to repurchase the property for P17,557.15 plus legal interest.
  4. Appeals and Execution:

    • The Rural Bank of Olongapo timely appealed the decision to the Court of Appeals.
    • Cayaba’s appeal was dismissed for being filed out of time, and his motion for reconsideration was also denied.
    • The trial court issued a writ of execution, which Cayaba challenged via certiorari to the Court of Appeals, but his petition was dismissed.

Issue:

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Ruling:

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Ratio:

  1. Interwoven Rights and Liabilities:

    • The general rule is that a reversal of a judgment on appeal binds only the parties who appealed. However, an exception exists when the rights and liabilities of the parties are so interwoven and dependent that a reversal as to one operates as a reversal to all.
    • In this case, Cayaba’s ownership of the property is derived from the Rural Bank of Olongapo. Therefore, the bank’s appeal directly affects Cayaba’s rights.
  2. Benefit of Appeal:

    • Citing Petilla v. Court of Appeals, the Court reiterated that a defendant may benefit from the judgment in favor of a co-defendant who appealed, especially when their liabilities are inseparable.
    • If the bank wins its appeal, Cayaba’s ownership of the property will be upheld.
  3. Restraint on Execution:

    • The trial court was restrained from enforcing the writ of execution pending the outcome of the bank’s appeal to ensure that Cayaba’s rights are not prejudiced prematurely.


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