Title
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.
A

Case Digest (G.R. No. 134269)

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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