Case Digest (G.R. No. 140608) Core Legal Reasoning Model
Facts:
In the civil case docketed as Civil Case No. 94-71639, petitioner Permanent Savings and Loan Bank sought to recover the principal sum of ₱1,000,000 plus accrued interest and penalties from respondent Mariano Velarde. The obligation allegedly arose from a loan secured by Velarde from the bank, evidenced by a promissory note dated September 28, 1983, a loan release sheet, and a loan disclosure statement all dated the same day. After the bank was placed under liquidation, it was represented by its Deputy Liquidator who sent Velarde a demand letter on July 27, 1988, for payment of the loan; Velarde did not settle the amount due.
A subsequent demand was sent on February 22, 1994, which elicited a reply from Velarde’s counsel denying the existence of the obligation, asserting that any promissory note or loan document did not bind Velarde as the net loan proceeds were received by another person, and the documents did not express the true intention of the parties. Velarde's answer
...
Case Digest (G.R. No. 140608) Expanded Legal Reasoning Model
Facts:
- Parties and Nature of the Case
- Petitioner: Permanent Savings and Loan Bank (PSLB), represented by its Deputy Liquidator after the bank was placed under liquidation.
- Respondent: Mariano Velarde.
- Case filed before the Regional Trial Court (RTC) of Manila, Branch 37, docketed as Civil Case No. 94-71639.
- Complaint: PSLB sought to recover P 1,000,000.00 plus accrued interests and penalties based on a loan obtained by Velarde, evidenced by:
- Promissory Note dated September 28, 1983.
- Loan Release Sheet dated September 28, 1983.
- Loan Disclosure Statement dated September 28, 1983.
- Demand and Respondent's Reaction
- Demand Letter sent on July 27, 1988, demanding full payment.
- Another demand sent on February 22, 1994.
- Response by respondent's counsel claimed no such obligation existed but was covered by a contemporaneous or subsequent agreement.
- Respondent's Answer
- Disclaimed any liability on the loan documents.
- Stated the signature on the promissory note seems to be his but the amount was received by another person; thus, he should not be held liable.
- Claimed documents did not express the true intention of the parties.
- Filed denial under oath stating the promissory note, even if genuine, does not bind him and does not express true intention.
- Trial Proceedings
- Pre-trial issues defined:
- Whether Velarde has an outstanding loan obligation.
- Whether Velarde is obligated to pay loan including interest and attorney’s fees.
- Whether Velarde executed the promissory note, considering doubt on signature genuineness and non-receipt of loan proceeds.
- Whether the obligation has prescribed due to lapse of time.
- Validity of respondent's counterclaim and damages.
- PSLB presented Antonio Marquez, Assistant Department Manager of the Philippine Deposit Insurance Corporation and Deputy Liquidator, who identified the loan documents.
- Respondent did not present evidence but filed a demurrer to evidence on grounds of failure to prove case by preponderance, and claimed the cause of action was barred by prescription.
- Decisions Below
- RTC granted demurrer to evidence, dismissing complaint and counterclaims (January 26, 1996).
- Court of Appeals (CA) affirmed dismissal (October 27, 1999), reasoning petitioner failed to prove existence of the loan and that the cause of action had prescribed.
- Petition for Review to the Supreme Court
- PSLB assigned errors that CA erred in:
- Holding that petitioner failed to establish genuineness and authenticity of loan documents.
- Holding that the cause of action was barred by prescription or laches.
Issues:
- Whether petitioner failed to establish the genuineness, due execution, and authenticity of the subject loan documents.
- Whether the petitioner’s cause of action is barred by prescription and/or laches.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)