Case Digest (G.R. No. 225920) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Felimon C. Torres v. Board of Trustees, Government Service Insurance System, G.R. No. 225920, decided April 3, 2024 under the 1987 Constitution, the petitioner, Felimon C. Torres, seeks to consolidate title to a low-cost housing unit originally acquired in 1979 through a Deed of Conditional Sale by his brother, Second Lieutenant Dominador dela Cena Torres, Jr., a Philippine Air Force pilot. Dominador obtained a GSIS-financed housing loan of ₱76,830.00 with monthly salary deductions but died in an accident while on duty on September 2, 1980. He neither underwent the required Sales Redemption Insurance (SRI) medical examinations nor paid SRI premiums. Unaware of his death until letters of delinquency went unanswered, GSIS issued a Notice of Foreclosure/Cancellation and ultimately canceled the conditional sale in September 2005. Petitioner, as sole heir by affidavit of adjudication, filed a petition with the GSIS Board on February 3, 2006 (GSIS Case No. 002-06), arguing that SRI Case Digest (G.R. No. 225920) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural History
- Petitioner Felimon C. Torres filed a Petition for Review on Certiorari under Rule 45 assailing the Court of Appeals’ Decision dated March 16, 2016 and Resolution dated July 20, 2016 in CA-G.R. SP No. 136562.
- The CA affirmed the GSIS Board of Trustees’ Decision of March 8, 2012 (GSIS Case No. 002-06) dismissing petitioner’s petition.
- Underlying Transaction and Death of Borrower
- In 1979, Second Lieutenant Dominador dela Cena Torres, Jr. (PAF pilot) entered into a Deed of Conditional Sale (DCS) for a low-cost housing unit in Muntinlupa City, financed by a GSIS housing loan of ₱76,830.00, payable via salary deductions.
- On September 2, 1980, Dominador died in a helicopter crash ruled “purely accidental,” intestate, single and without issue; survived by his parents.
- Post-mortem Loan Correspondence and Petitioner’s Actions
- GSIS, unaware of Dominador’s death, sent letters and a Notice of Foreclosure (1988) for unpaid amortizations, then a Notice of Cancellation (2005).
- Petitioner—Dominador’s sole heir by affidavit of adjudication—claimed Sales Redemption Insurance (SRI) coverage in letters (1989-1990); GSIS denied for lack of medical exam and premium payment.
- On February 3, 2006, petitioner filed before the GSIS Board a petition to consolidate title in his name or, alternatively, settle loan on original purchase price; petition was denied. Petitioner appealed to the CA, which dismissed for lack of merit.
Issues:
- Whether Dominador’s DCS was covered by the compulsory Sales Redemption Insurance despite his failure to undergo GSIS medical examinations and payment of SRI premiums.
- Whether the cancellation of the DCS and the demand to vacate are warranted, or whether petitioner—as sole heir—may avail himself of the Housing Loan Remedial and Restructuring Program under GSIS Resolution No. 48 (PPG No. 232-13).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)