Case Digest (G.R. No. 161713)
Facts:
In PHILIPPINE NATIONAL BANK v. COURT OF FIRST INSTANCE OF RIZAL (G.R. No. 63201, May 27, 1992), private respondents Chung Siong Pek @ Bonifacio Chung Siong Pek and Victoria Ching Geng Ty @ Victoria Cheng Geng Ty owned three parcels of land in Pasig, Metro Manila (OCT No. 853; TCT Nos. 32843 and 32897). On March 1, 1954, they leased these parcels to Philippine Blooming Mills, Co., Inc. (PBM), a corporation duly incorporated on January 19, 1952 for a twenty-five-year term, for use as a factory site for twenty years with an option to renew for another twenty years if PBM extended its corporate life. PBM constructed buildings and improvements which were registered and annotated on the titles. On October 11, 1963, PBM assigned its leasehold rights to Philippine National Bank (PNB) as security for loans, and on November 6 and December 23, 1963 mortgaged the improvements to PNB. PBM filed a petition (LRC Case No. 6530) for registration of improvements. On October 7, 1981, private respoCase Digest (G.R. No. 161713)
Facts:
- Ownership and Lease
- Private respondents are registered owners of three parcels of land in Pasig, Metro Manila (OCT No. 853; TCT Nos. 32843, 32897).
- On March 1, 1954, they leased the parcels to Philippine Blooming Mills, Co., Inc. (PBM) for twenty (20) years, with an option to renew for another twenty (20) years if PBM’s corporate existence was extended in accordance with law.
- Assignment, Mortgages and Improvements
- PBM erected buildings, machinery and other improvements, duly annotated as Entry No. 85213/T-No. 43338.
- On October 11, 1963, PBM assigned its leasehold rights to Philippine National Bank (PNB) (Entry No. 85215/T-No. 32843).
- On November 6 and December 23, 1963, PBM mortgaged its improvements in favor of PNB covering loans of ₱100,000 and ₱1,590,000, annotated as Entry Nos. 85214/T-No. 43338 and 87097/T-No. 32843.
- Proceedings Below
- PBM petitioned under LRC Case No. 6530 for registration of improvements. On October 7, 1981, private respondents filed a motion (docketed as LRC Case No. R-2744) to cancel all annotations—assignment, mortgages, improvements—alleging the lease expired March 1, 1974, PBM’s corporate term expired January 19, 1977, and improvements were not removed.
- Respondent CFI of Rizal issued orders:
- April 22, 1982: directed cancellation of the entries upon payment of fees.
- June 28, 1982: denied PNB’s motion for reconsideration.
- September 14, 1982: granted private respondents’ motion for entry of final judgment and writ of execution.
- January 12, 1983: denied PNB’s omnibus motion contesting lack of notice.
Issues:
- Notice and Due Process
- Whether the trial court issued final orders without actual notice to PNB and abused its discretion by relying solely on the postmaster’s certification.
- Jurisdiction
- Whether the Securities and Exchange Commission (SEC) had exclusive jurisdiction over questions concerning PBM’s corporate existence, precluding the trial court’s action.
- Lease Expiration and Corporate Term
- Whether PBM validly exercised its option to renew the lease and extended its corporate existence.
- Ownership of Improvements
- Whether upon lease termination the improvements accrue to private respondents and cancellation of PNB’s entries was proper.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)