Case Digest (G.R. No. 184843) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On November 29, 1985, Goldenway Merchandising Corporation (petitioner) executed a real estate mortgage over three parcels in Valenzuela City to secure a ₱2,000,000 loan from Equitable PCI Bank (respondent), and the mortgage was duly registered. After petitioner’s default, respondent extrajudicially foreclosed on December 13, 2000, bought the properties for ₱3,500,000, and had the Certificate of Sale registered on February 16, 2001, inscribed on the relevant Transfer Certificates of Title. Petitioner’s counsel offered to redeem the properties on March 8, 2001, and renewed the offer on March 12, but was informed redemption was barred by the registration of the certificate, which new titles in respondent’s name were already issued. On December 7, 2001, petitioner sued for specific performance and damages, arguing that the one-year redemption period under Act No. 3135 applied and that Section 47 of R.A. 8791 impaired its vested contractual right and violated equal protection. The Re Case Digest (G.R. No. 184843) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Mortgage Execution and Foreclosure
- On November 29, 1985, Goldenway Merchandising Corporation (petitioner) executed a real estate mortgage over properties in Valenzuela City (TCT Nos. T-152630, T-151655, T-214528) securing a ₱2,000,000 loan from Equitable PCI Bank (respondent).
- After petitioner’s default, respondent extrajudicially foreclosed on December 13, 2000; properties sold to respondent for ₱3,500,000; Certificate of Sale issued January 26, 2001 and registered February 16, 2001.
- Redemption Attempts and Initial Complaint
- March 8–12, 2001: Petitioner’s counsel tendered a check for ₱3,500,000 and sought to redeem but was informed redemption was no longer possible due to registration of the Certificate of Sale; new titles in respondent’s name issued March 9, 2001.
- December 7, 2001: Petitioner filed a complaint for specific performance and damages, asserting applicability of the one-year redemption period under Act No. 3135, challenging the shorter three-month period for juridical persons under RA 8791, and alleging failure to provide a statement of account.
- Trial and Appellate Proceedings
- RTC (Jan. 8, 2007): Dismissed petitioner’s complaint and respondent’s counterclaim; held redemption was untimely and unauthorized; noted constitutional issue not raised in trial.
- CA (Nov. 19, 2010; Resolution Jan. 31, 2011): Affirmed RTC; applied Section 47, RA 8791; found petitioner failed to establish unconstitutionality and that the shortened redemption period governs juridical persons.
Issues:
- Applicability of Section 47, RA 8791’s shortened redemption period to a mortgage executed in 1985 but foreclosed after RA 8791’s effectivity.
- Whether Section 47 violates the constitutional prohibition against impairment of contracts.
- Whether Section 47 violates equal protection by treating juridical persons differently.
- Whether RA 8791 should be applied retroactively over the special law (Act No. 3135).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)