Title
Supreme Court
Metropolitan Bank and Trust Company vs. International Exchange Bank
Case
G.R. No. 176008
Decision Date
Aug 10, 2011
Consolidated petitions regarding the annulment of RTC orders for intervention in a loan dispute involving chattel mortgages and claims of fraud by creditors.

Case Digest (G.R. No. 176008)
Expanded Legal Reasoning Model

Facts:

  • Background and Parties Involved
    • Sacramento Steel Corporation (SSC) is engaged in manufacturing steel products at its plant in Tagoloan, Misamis Oriental.
    • SSC entered into credit agreements with International Exchange Bank (IEB), receiving credit lines and loans totaling up to P180,000,000.00.
    • SSC secured loan obligations via five chattel mortgages over various equipment dated between September 17, 2001, and June 7, 2004.
  • Default and Initial Legal Actions
    • SSC defaulted on its loan obligations with IEB.
    • IEB filed an injunction action with the RTC of Misamis Oriental to prevent SSC from removing mortgaged equipment (Civil Case No. 2004-197).
    • IEB filed a Supplemental Complaint seeking issuance of a writ of replevin or payment of obligations.
    • SSC filed a Complaint for annulment of mortgage, specific performance to compel loan restructuring, and prayed for Temporary Restraining Order (TRO) and preliminary injunction against IEB's foreclosure efforts (Civil Case No. 2004-200).
  • RTC Orders and Proceedings
    • The RTC issued a TRO in favor of SSC.
    • RTC granted IEB's application for writ of replevin but held its implementation in abeyance pending further court resolution.
    • RTC ordered "no commercial operation without court approval."
    • IEB filed a petition for extrajudicial foreclosure, opposed by SSC, which sought a preliminary injunction.
    • On September 6, 2004, RTC issued a preliminary injunction restraining IEB from foreclosing or dispossessing SSC from mortgaged equipment, pending case resolution.
  • Events Involving Third Parties
    • On August 30, 2004, SSC entered into a Capacity Lease Agreement with Chuayuco Steel Manufacturing Corporation (CSMC) allowing operation of cold rolling and galvanizing plants.
    • Metropolitan Bank and Trust Company (Metrobank) intervened, claiming an interest as SSC's creditor and alleging the mortgages were made to defraud creditors, praying for rescission of the mortgages.
    • CSMC moved to intervene, seeking approval to operate the plants under the lease agreement.
    • RTC admitted both Metrobank and CSMC's motions to intervene.
    • RTC granted CSMC's motion to operate the plants pendente lite.
    • RTC ordered CSMC to file a complaint-in-intervention.
  • Appeals
    • IEB filed a petition for certiorari, prohibition, and mandamus with the CA, assailing the RTC's orders admitting intervention and allowing plant operation by CSMC and restraining foreclosure by IEB.
    • The CA annulled and set aside the RTC’s orders and directed return of properties to IEB.
    • Motions for reconsideration by Metrobank, CSMC, and SSC were denied by the CA.
    • Metrobank was substituted by Meridian (SPV-AMCI) Corporation as petitioner.
  • Issues Raised
    • Metrobank alleged the CA erred in ruling its complaint-in-intervention is an accion pauliana and that the RTC abused discretion in admitting the intervention.
    • CSMC contended IEB was guilty of forum shopping; that failure to file motion for reconsideration against the RTC’s June 8, 2005 order was fatal; and that the RTC erred in admitting CSMC’s intervention.

Issues:

  • Whether Metrobank’s complaint-in-intervention is an accion pauliana requiring exhaustion of other legal remedies or whether the RTC erred in admitting its intervention.
  • Whether IEB was guilty of forum shopping in its multiple filings related to the Capacity Lease Agreement and litigation over mortgaged equipment.
  • Whether failure by IEB to file a motion for reconsideration of the RTC’s June 8, 2005 order judicially estops or bars its petition for certiorari.
  • Whether the RTC properly admitted CSMC’s intervention and whether CSMC’s legal interest warrants such intervention.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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