Case Digest (G.R. No. 135644)
Facts:
- In December 1969, Gonzalo (deceased) and Matilde Labung-Deang obtained a PHP 8,500 housing loan from the Government Service Insurance System (GSIS).
- The loan was secured by a real estate mortgage on their property covered by Transfer Certificate of Title No. 14926-R, set to mature on December 23, 1979.
- The spouses deposited the owner's duplicate copy of the title with GSIS as per the mortgage deed requirement.
- On January 19, 1979, the spouses fully settled their debt and requested the return of the owner's duplicate copy to secure a new PHP 50,000 loan from a private lender, Milagros Runes.
- GSIS personnel failed to locate the title despite diligent search efforts.
- GSIS initiated reconstitution proceedings in 1979 and released the reconstituted title on June 26, 1979.
- The spouses filed a complaint for damages against GSIS on July 6, 1979, claiming the delay hindered them from obtaining the new loan, resulting in financial loss.
- The Regional Trial Court of Angeles City ruled in favor of the spouses on July 31, 1995, awarding PHP 20,000 in temperate damages, PHP 15,000 in attorney's fees, legal interest, and costs of the suit.
- GSIS appealed, but the Court of Appeals affirmed the trial court's decision on September 21, 1998.
- GSIS subsequently brought the case to the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that GSIS is liable for damages and denied the petition for lack of merit.
- The Court affirmed the decision of the Court of Appeals with ...(Unlock)
Ratio:
- The Supreme Court held that the sixth paragraph of Article 2180 of the Civil Code, which exempts the State from vicarious liability for the acts of its employees, does not apply to GSIS.
- GSIS, as a GOCC with a separate legal personality, is liable for damages caused by its employees acting within the scope of their tasks.
- The obligation of GSIS arose from a pre-existing contract with the spouses Deang, specifically the loan agreement secured by a real estate mortgage.
- The duty to return the owner's duplicate copy of the title arose upon the release of ...continue reading
Case Digest (G.R. No. 135644)
Facts:
In the case of "Government Service Insurance System v. Spouses Labung-Deang," the respondents, Gonzalo (now deceased) and Matilde Labung-Deang, obtained a housing loan of PHP 8,500 from the Government Service Insurance System (GSIS) in December 1969. The loan was secured by a real estate mortgage on their property covered by Transfer Certificate of Title No. 14926-R and was set to mature on December 23, 1979. The spouses deposited the owner's duplicate copy of the title with GSIS as required by the mortgage deed. On January 19, 1979, the spouses settled their debt and requested the return of the owner's duplicate copy of the title to secure a new loan of PHP 50,000 from a private lender, Milagros Runes, for house renovation and business purposes. However, GSIS personnel could not locate the title despite diligent search efforts. Consequently, GSIS initiated reconstitution proceedings in 1979 and eventually released the reconstituted title on June 26, 1979. The spouses filed a complaint for damages against GSIS on July 6, 1979, claiming that the delay in releasing the title prevented them from securing the loan, causing financial loss. The Regional Trial Court of Angeles City ruled in favor of the spouses on July 31, 1995, awarding them PHP 20,000 in temperate damages, PHP 15...