Case Digest (G.R. No. 201892) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Norlinda S. Marilag v. Marcelino B. Martinez (G.R. No. 201892, July 22, 2015), petitioner Marilag extended a loan of ₱160,000.00 to Rafael Martinez on July 30, 1992, secured by a real estate mortgage on TCT No. T-208400 with a stipulated interest of 5% per month, payable in six months. Rafael defaulted, and on November 10, 1995, Marilag filed a judicial foreclosure suit (RTC-Imus, Cavite, Civil Case No. 1208-95). Rafael was declared in default, and on January 30, 1998, the RTC-Imus reduced the interest to 12% per annum and adjudged a total due of ₱229,200.00 (₱160,000.00 principal plus interest). Before learning of that decision, respondent Martinez—Rafael’s son—paid ₱400,000.00 and executed a promissory note on February 20, 1998 for the remaining ₱289,000.00 balance. When Marilag demanded payment, Martinez refused on the ground of overpayment based on the foreclosure judgment and counterclaimed for return of the excess. On July 2, 1998, Marilag filed a collection suit (RTC-L Case Digest (G.R. No. 201892) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Loan Agreement and Foreclosure Proceedings
- On July 30, 1992, Rafael Martinez obtained a loan of ₱160,000 from Norlinda S. Marilag, with a stipulated 5% monthly interest for six months, secured by real estate mortgage (TCT No. T-208400).
- After Rafael defaulted, petitioner filed a judicial foreclosure case (RTC-Imus, CC No. 1208-95) on November 10, 1995. Rafael was declared in default and, by Decision dated January 30, 1998, the RTC-Imus reduced the interest to 12% p.a. and adjudged Rafael liable for ₱229,200 (₱160,000 principal + ₱59,200 interest).
- Respondent’s Assumption of Debt and Collection Suit
- Before learning of the January 30, 1998 decision, respondent Marcelino Martinez agreed to pay Rafael’s obligation, paid ₱400,000, and on February 20, 1998 executed a promissory note promising to pay the ₱289,000 balance by March 31, 1998.
- Upon discovering the foreclosure decision fixed the debt at ₱229,200, respondent refused further payment. Petitioner filed a collection suit (RTC Las Piñas, CC No. 98-0156) on July 2, 1998. Respondent answered, denied cause of action, and counterclaimed for return of the alleged excess payment and damages.
- Rulings of the Regional Trial Court
- Decision dated August 28, 2003: The RTC held that the foreclosure decision extinguished the debt; found an overpayment of ₱171,000; declared a quasi-contract (solutio indebiti) and ordered petitioner to return the excess plus 6% interest from August 6, 1998, with attorney’s fees and costs.
- Orders dated November 3, 2003 and January 14, 2004: Upon reconsideration, the RTC reversed itself, ruled foreclosure and collection are distinct, upheld the 5% monthly interest, and directed respondent to pay ₱289,000 plus legal interest, attorney’s fees, and costs.
- Court of Appeals Decision
- Decision dated November 4, 2011: The CA set aside the RTC’s November 3 and January 14 orders, reinstated the August 28, 2003 Decision, and held the collection suit barred by res judicata.
- Resolution dated May 14, 2012: The CA denied petitioner’s motion for reconsideration.
Issues:
- Whether the Court of Appeals erred in dismissing the collection case on grounds of res judicata (and/or litis pendentia).
- Whether respondent’s counterclaim for return of excess payments should be sustained and on what terms.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)