Case Digest (G.R. No. 170352) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1993, New Frontier Sugar Corporation (NFSC) secured a loan from Equitable PCI Bank (EPCIB), pledging a 92‐hectare land in Passi City, Iloilo, and its sugar mill. Due to financial distress, on November 17, 2000, NFSC entered into a three‐year Memorandum of Agreement (MOA) with Central Iloilo Milling Corporation (CIMICO) for CIMICO to manage NFSC’s sugar factory. In April 2002, NFSC sued CIMICO for breach of the MOA (Civil Case No. 02-240), prompting CIMICO to counterclaim for sums due (Civil Case No. 02-243) before the Regional Trial Court (RTC) of Dumangas, Branch 68. Meanwhile, EPCIB foreclosed extrajudicially on May 10, 2002, became the sole bidder at the auction, consolidated the titles, and sought possession through the Philippine Industrial Security Agency (PISA). CIMICO secured a restraining order on September 25, 2002, maintaining its possession. On October 3, 2002, Megan Sugar Corporation (“MEGAN”) and CIMICO executed an MOA whereby MEGAN assumed CIMICO’s rights and o Case Digest (G.R. No. 170352) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Indebtedness and Security Arrangements
- On July 23, 1993, New Frontier Sugar Corporation (NFSC) obtained a loan from Equitable PCI Bank (EPCIB), secured by a real estate mortgage covering 92 hectares in Passi City, Iloilo, and a chattel mortgage on NFSC’s sugar mill.
- On November 17, 2000, due to liquidity problems, NFSC entered into a Memorandum of Agreement (MOA) with Central Iloilo Milling Corporation (CIMICO), whereby CIMICO took over operation and management of NFSC’s raw sugar factory for crop years 2000–2003.
- Foreclosure Proceedings and RTC Restraining Order
- On May 10, 2002, EPCIB foreclosed extrajudicially on NFSC’s mortgaged land and mill; EPCIB was sole bidder at public auction and consolidated titles.
- CIMICO filed an Amended Complaint on September 16, 2002, impleading EPCIB and PISA; on September 25, 2002, the RTC issued a restraining order preventing EPCIB and PISA from taking possession, preserving CIMICO’s occupancy.
- MEGAN Sugar Corporation’s Involvement
- On October 3, 2002, MEGAN Sugar Corporation (MEGAN) assumed CIMICO’s rights and obligations under the MOA and commenced mill operations on November 18, 2002.
- From November to December 2002, Passi Iloilo Sugar Central, Inc. sought intervention; EPCIB, Passi Sugar, and NFSC filed motions to deposit the miller’s share in escrow; on January 16, 2003, the RTC ordered MEGAN to deposit sugar quedans representing the miller’s share.
- Procedural History and Appeals
- MEGAN, through Atty. Reuben Mikhail Sabig (without board resolution), filed an Omnibus Motion for Reconsideration on January 29, 2003, which the RTC denied on February 19, 2003, then granted EPCIB’s ex parte execution on February 28, 2003.
- MEGAN petitioned the Court of Appeals (CA) for certiorari; on August 23, 2004, the CA dismissed the petition for lack of merit and denied reconsideration on October 12, 2005. MEGAN elevated the case to the Supreme Court raising estoppel and jurisdiction issues.
Issues:
- Whether MEGAN is estopped from assailing the RTC orders due to the acts and representations of Atty. Sabig.
- Whether the RTC had jurisdiction to issue the January 16, 2003, February 19, 2003, and February 28, 2003 orders against MEGAN.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)