Case Digest (G.R. No. 202448) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In First Sarmiento Property Holdings, Inc. v. Philippine Bank of Communications (G.R. No. 202836, June 19, 2018), the petitioner, First Sarmiento Property Holdings, Inc., secured from respondent Philippine Bank of Communications (PBCOM) on June 19, 2002, a ₱40,000,000 loan collateralized by real estate mortgages over 1,076 parcels in Bulacan. The loan was amended twice in 2003, raising the principal to ₱100,000,000. When First Sarmiento allegedly defaulted, PBCOM filed an extrajudicial foreclosure petition on January 2, 2006, and, after auctioning the properties on December 29, 2011, obtained a certificate of sale on January 24, 2012. Before registration of that certificate, First Sarmiento filed on January 2, 2012, a Complaint for annulment of real estate mortgage and amendments, with a prayer for a 72-hour ex-parte temporary restraining order (TRO) and preliminary injunction, paying only ₱5,545 docket fees based on the Executive Judge’s determination that the action was “incap Case Digest (G.R. No. 202448) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Loan and Mortgage Agreements
- On June 19, 2002, First Sarmiento Property Holdings, Inc. obtained a ₱40,000,000 loan from PBCOM secured by a real‐estate mortgage over 1,076 parcels of land.
- The loan was amended on March 15, 2003 (increased to ₱51,200,000) and on September 15, 2003 (increased to ₱100,000,000).
- On January 2, 2006, PBCOM filed a Petition for Extrajudicial Foreclosure due to petitioner’s failure to pay principal and accrued interest.
- Attempts to Annul and Extrajudicial Sale
- December 27, 2011: Petitioner tried to file a Complaint for annulment of the mortgage; the Clerk of Court refused it for lack of tax declarations to assess docket fees.
- December 29, 2011: RTC (Malolos City) granted petitioner’s motion to treat the action as non-pecuniary and issued a 72-hour ex-parte TRO; on the same day, the mortgaged properties were auctioned and sold to PBCOM.
- Trial Court Proceedings
- January 2, 2012: Petitioner filed the Complaint for annulment of mortgage with prayer for TRO and preliminary injunction, paying ₱5,545 in filing fees; the court issued the 72-hour ex-parte TRO.
- January 4, 2012: RTC directed the parties to maintain status quo ante; January 24, 2012: Sheriff issued the certificate of sale in favor of PBCOM.
- April 3, 2012: RTC Branch 11 dismissed the Complaint for lack of jurisdiction due to alleged insufficient fees; July 25, 2012: motion for reconsideration denied.
- Supreme Court Petition and Party Positions
- August 17, 2012: Petitioner filed a Petition for Review on Certiorari (Rule 45), asserting the action was incapable of pecuniary estimation.
- PBCOM contended the case was a real action requiring fees based on the fair market value of the properties and challenged the indefinite TRO.
- Both parties filed memoranda and replies; the focal issue became whether the RTC had subject‐matter jurisdiction over the Complaint.
Issues:
- Jurisdiction
- Whether the Regional Trial Court acquired jurisdiction over petitioner’s Complaint for annulment of real estate mortgage given the docket fees paid.
- Injunctive Relief
- Whether the RTC’s order indefinitely extending the ex-parte TRO and directing status quo ante was lawful under the Rules of Court.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)