Case Digest (G.R. No. 104528)
Facts:
In Philippine National Bank v. Office of the President, Housing and Land Use Regulatory Board, et al. (G.R. No. 104528, January 18, 1996), private respondents Alfonso and Angelina Maglaya, Jorge Bernardino, Corazon De Leon, and others entered into installment land purchase agreements with Marikina Village, Inc., and constructed homes on individual lot parcels. Unbeknownst to them, the developer had earlier, on December 18, 1975, mortgaged the same subdivision lots to the petitioner, Philippine National Bank (PNB). After the developer defaulted on its mortgage obligations, PNB foreclosed, became the highest bidder, and sought to dispossess the installment buyers unless they paid in full again. The buyers separately filed suits before the Housing and Land Use Regulatory Board (HLURB) Office of Appeals, Adjudication and Legal Affairs, which on October 28, 1988 ruled that PNB could only collect the remaining installments under the original agreements and could not compel full repurcCase Digest (G.R. No. 104528)
Facts:
- Parties
- Petitioner: Philippine National Bank (PNB), mortgagee of subdivision lots.
- Respondents: Private buyers on installment (Alfonso Maglaya, Angelina Maglaya P. Reyes, et al.) from Marikina Village, Inc., represented by attorney-in-fact.
- Transactional Background
- Private respondents entered into land purchase agreements with Marikina Village, Inc., paid installments, and built houses, unaware of any encumbrance.
- On December 18, 1975, the subdivision developer mortgaged the same lots to PNB and later defaulted.
- PNB foreclosed the mortgage and became highest bidder at the foreclosure sale, acquiring title over the lots.
- Administrative and Executive Proceedings
- HLURB Office of Appeals, Adjudication and Legal Affairs (OAALA) Decision (Oct. 28, 1988): PNB may only collect remaining amortizations due under respondents’ agreements and cannot demand full payments anew.
- Housing and Land Use Regulatory Board Affirmation (May 2, 1989): Upheld the OAALA decision.
- Office of the President Resolution (Mar. 10, 1992): Invoked P.D. 957 and concurred with HLURB, ruling PNB must accept remaining payments.
- Supreme Court Petition
- PNB filed a petition for certiorari and prohibition before the Supreme Court, challenging the Office of the President’s Resolution.
- PNB invoked Revised Administrative Circular No. 1-95 but the Supreme Court granted direct review in the interest of speedy justice.
Issues:
- Retroactivity of P.D. 957
- Whether P.D. 957 (“Subdivision and Condominium Buyers’ Protective Decree”), enacted July 12, 1976, applies to a mortgage contract executed on December 18, 1975.
- Privity of Contracts
- Whether PNB, as a stranger to the land purchase agreements between respondents and the subdivision developer, can be compelled to accept respondents’ remaining amortizations and issue titles.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)