Title
Mendoza vs. Court of Appeals, 8th Division
Case
G.R. No. 182814
Decision Date
Jul 15, 2015
The Supreme Court upheld valid service of judgment to counsel in a loan default and foreclosure matter, reinforcing the principle of finality in legal proceedings.
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Case Digest (G.R. No. 182814)

Facts:

  • Petitioners Ligaya Mendoza and Adelia Mendoza filed a case against the Honorable Court of Appeals (Eighth Division), Judge Liberato C. Cortez, and Bangko Kabayan (formerly Ibaan Rural Bank, Inc.).
  • On September 4, 1997, the petitioners obtained a loan of P12,000,000.00 from Bangko Kabayan, secured by a Promissory Note.
  • They executed a Deed of Real Estate Mortgage over 71 parcels of land registered in their names in Mabini, Batangas.
  • The petitioners defaulted on the loan, leading the bank to file a Complaint for Judicial Foreclosure on May 21, 1998, in the Regional Trial Court (RTC) of Batangas City.
  • The RTC issued a Judgment on the Pleadings on March 7, 2002, ordering the petitioners to pay the bank within 90 days or face public auction of their properties.
  • The petitioners did not appeal or file a motion for reconsideration within the required timeframe.
  • The bank subsequently filed a Motion for Execution, which the petitioners opposed, claiming lack of proper service of the RTC decision.
  • The RTC denied their opposition on May 28, 2003, citing negligence on the part of the petitioners' counsel.
  • The Court of Appeals affirmed the RTC's order on November 29, 2007, and denied a Motion for Reconsideration on April 28, 2008.
  • The petitioners then filed a Petition for Certiorari against the appellate court's decision.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court dismissed the petition, affirming the decision and resolution of the Court of Appeals.
  • The Court ruled that there was valid service of the RTC judgment to the petitioners, and the negligence of their counsel was binding on them.
  • The Court found n...(Unlock)

Ratio:

  • The Supreme Court emphasized that all notices and orders must be served to the attorney of record when a party is represented by counsel.
  • The judgment was duly delivered to the address of the petitioners' counsel, as confirmed by the Postmaster General's certification...continue reading

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