Title
Navarro vs. Metropolitan Bank and Trust Company
Case
G.R. No. 165697
Decision Date
Aug 4, 2009
A wife challenges fraudulent property mortgage by her husband, but her claims are barred by laches and res judicata, upheld by the Supreme Court.

Case Digest (G.R. No. 155043)
Expanded Legal Reasoning

Facts:

# Marriage and Property Acquisition

Petitioners Antonio Navarro and Clarita Navarro were married on December 7, 1968. During their marriage, they acquired three parcels of land in Alabang, Muntinlupa City, which were covered by Transfer Certificate of Title (TCT) Nos. 155256, 155257, and 155258. However, the titles were registered in the name of "Antonio N. Navarro... married to Belen B. Navarro."

# Mortgage and Foreclosure

In 1998, respondent Metropolitan Bank and Trust Company (MBTC) initiated the judicial foreclosure of a real estate mortgage on the properties, which Antonio had earlier constituted as security for a loan. The properties were sold at a public auction, with MBTC as the lone bidder, and a certificate of sale was issued.

# First Legal Action (Civil Case No. 99-177)

Clarita filed a complaint before the Regional Trial Court (RTC) of Muntinlupa City, Branch 256, seeking the declaration of nullity of the real estate mortgage and the foreclosure sale. She alleged that the properties were conjugal and that Antonio, with the connivance of Belen, had fraudulently registered and mortgaged them without her knowledge. MBTC moved to dismiss the complaint on the ground of laches, and the Court of Appeals granted the motion, dismissing the case.

# Second Legal Action (Civil Case No. 02-079)

Clarita filed another complaint in 2002, this time seeking the declaration of nullity of the TCTs and reconveyance of her conjugal share in the properties. MBTC again moved to dismiss, arguing that the complaint was barred by the prior judgment in Civil Case No. 99-177. The trial court denied the motion, but the Court of Appeals reversed the decision, ordering the dismissal of the complaint on the ground of laches and res judicata.

# Compromise Agreement

During the proceedings, Antonio and Clarita entered into a compromise agreement, wherein Clarita waived her claims against Antonio, and Antonio acknowledged her share in the properties. The trial court approved the compromise, leaving MBTC as the sole defendant.

Issues:

  • Whether the dismissal of Civil Case No. 99-177 on the ground of laches bars the filing of Civil Case No. 02-079.
  • Whether the principle of laches applies to an action for the declaration of nullity of a mortgage contract.
  • Whether the Court of Appeals erred in dismissing Civil Case No. 02-079 based on res judicata.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)
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