Case Digest (G.R. No. 217860) Core Legal Reasoning Model
Facts:
The case involves a dispute between Spouses Leonardo Lontoc and Nancy Lontoc (petitioners) and Spouses Roselie Tiglao and Tomas Tiglao, Jr. (respondents) concerning the judicial foreclosure of a mortgage over certain real property in Pasig City. The litigation began with a complaint for nullification of a deed of absolute sale filed by the Tiglaos against the Lontocs. On December 20, 1999, RTC Branch 158 in Pasig City declared the deed of sale to be an equitable mortgage and allowed the Tiglaos a three-month period from finality of the decision to redeem the property by paying PHP 300,000.00. This decision was modified by the Court of Appeals on December 17, 2004, which affirmed the equitable mortgage status but set aside the order to pay PHP 1,043,205.00 counterclaim. The Lontocs’ motion for reconsideration to the Supreme Court was denied, making the decision final and executory on January 18, 2006.
The Tiglaos failed to pay the PHP 300,000.00 within the three-month period. Su
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Case Digest (G.R. No. 217860) Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Spouses Roselie Tiglao and Tomas Tiglao, Jr. (respondents) filed a complaint to nullify a Deed of Absolute Sale executed in favor of spouses Leonardo Lontoc and Nancy Lontoc (petitioners).
- The Regional Trial Court (RTC), Branch 158, Pasig City, ruled on December 20, 1999, that the deed was actually an equitable mortgage and allowed spouses Tiglao three (3) months from finality of judgment to redeem the property for PHP 300,000.00.
- The Court of Appeals (CA) on December 17, 2004, affirmed the equitable mortgage ruling, setting aside the counterclaim for PHP 1,043,205.00.
- Spouses Lontoc’s appeal to the Supreme Court was denied final and executory on January 18, 2006.
- Subsequent Proceedings and Foreclosure
- As spouses Tiglao failed to pay the redemption amount, spouses Lontoc filed a foreclosure complaint praying:
- Order spouses Tiglao to pay PHP 300,000.00 plus 12% legal interest and attorney’s fees within 90 days;
- In case of default, order sale of the foreclosed property.
- The case was raffled to RTC, Branch 153.
- The RTC issued a decision on February 17, 2011, declaring the property foreclosed and awarding attorney’s fees of PHP 60,000.00 but failed to specify the amount due or the period to pay.
- Both parties did not appeal, making the decision final and executory.
- Execution and Related Orders
- Spouses Tiglao filed a Motion for Execution on April 25, 2011, pointing out the February 2011 decision’s silence on execution details and prayed for a writ requiring payment of PHP 360,000.00 within 90 days.
- The RTC granted the Motion on June 24, 2011, and issued a writ of execution on July 8, 2011, ordering payment of PHP 360,000.00 within 120 days.
- Spouses Lontoc filed a Motion for Reconsideration or Partial Clarification, arguing that the writ was invalid because of failure to include the redemption period and because the writ amended the judgment improperly. This motion was denied on August 2, 2011.
- Sheriff’s Report indicated spouses Tiglao paid PHP 360,000.00 on July 22, 2011.
- Spouses Tiglao filed a Motion for Issuance of Writ of Possession on August 22, 2011.
- Spouses Lontoc urged Sheriff to conduct auction sale through a letter dated September 5, 2011.
- RTC, Branch 153 on November 28, 2011, issued an Order:
- Denied spouses Tiglao’s Motion for Writ of Possession;
- Declared the July 8, 2011 Writ of Execution null and void and recalled it;
- Directed public auction sale of the property;
- Ordered refund of PHP 300,000.00 to spouses Tiglao and release of PHP 60,000.00 attorney’s fees to spouses Lontoc.
- Spouses Tiglao’s motion for reconsideration was denied on March 19, 2012.
- Court of Appeals Proceedings and Decision
- Spouses Tiglao filed a Petition for Certiorari and Mandamus before the CA.
- The CA granted the petition on September 10, 2014, setting aside the RTC orders denying the writ of possession and directing the issuance of the writ of possession and to continue foreclosure proceedings in compliance with Rule 68, Sections 2 and 3 of the Rules of Court.
- The CA held that the RTC violated the procedure for execution of judicial foreclosure by:
- Denying the writ of possession without proper grounds;
- Recalling the writ of execution;
- Ordering auction sale prematurely without granting spouses Tiglao the equity period.
- Spouses Lontoc moved for reconsideration which the CA denied on April 6, 2015.
- Present Petition and Contentions
- Spouses Lontoc filed a Petition for Review on Certiorari to the Supreme Court challenging the CA Decision and Resolution.
- They argue that:
- The CA erred for violating the principle of immutability of judgment by allowing spouses Tiglao another redemption period after their three-month period lapsed;
- The sum fixed in the Writ of Execution (PHP 360,000.00) was not supported by the February 17, 2011 Decision;
- The payment of spouses Tiglao cannot delay enforcement or invalidate the foreclosure.
- Spouses Tiglao maintain that the RTC’s June 24, 2011 Order granting them an equity period of 120 days to pay PHP 360,000.00 conformed with Rule 68, Section 2, and the payment made was valid.
- They assert that the RTC’s November 28, 2011 Order directing auction sale is contrary to law and the equity of redemption concept.
Issues:
- Whether the February 17, 2011 Decision of RTC, Branch 153 was valid and executable despite failing to specify the amount due and period for payment as required by Rule 68, Section 2 of the Rules of Court.
- Whether spouses Tiglao lost their right or equity of redemption by failing to pay within the three-month period set by prior decisions.
- Whether the April 25, 2011 Motion for Execution filed by spouses Tiglao and the consequent July 8, 2011 Writ of Execution were proper and valid.
- Whether the RTC committed reversible error in denying spouses Tiglao’s Motion for Writ of Possession and ordering the sale of the property despite the alleged payment.
- Whether the CA erred in setting aside the RTC orders and directing issuance of the writ of possession in favor of spouses Tiglao.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)