G.R. No. 193346 - Philippine National Bank vs. Spouses Rogelio and Evelyn Roque

Philippine National Bank (PNB) filed a Petition for Review on Certiorari before the Supreme Court, assailing the Court of Appeals (CA) Decision and Resolution.
Respondents are Spouses Rogelio and Evelyn Roque (Spouses Roque), who executed real estate mortgages over five properties to secure their loans from PNB.

Spouses Roque mortgaged two lots in Valencia City, Bukidnon, and three lots in Cagayan de Oro City to secure their loans from PNB.
By August 31, 2001, the total loan obligation secured by the mortgages amounted to Php16,534,803.29.
The Spouses Roque failed to pay their loans upon maturity.

PNB filed petitions for extrajudicial foreclosure for the properties in Cagayan de Oro City (filed Nov 21, 2002) and Valencia City (filed Nov 22, 2002) before their respective RTCs.
Public auctions were held on January 15, 2003, separately for Cagayan de Oro and Valencia City properties.
PNB was the sole bidder in both auctions and submitted a combined bid amounting to Php33,069,606.58: Php16,534,803.29 for each group of properties.
Certificates of Sale were issued in favor of PNB for both auctions.

On October 23, 2003, Spouses Roque filed a Complaint for Annulment of Sale, Cancellation of Certificate of Sale, Injunction, and Damages before the RTC of Malaybalay City, seeking annulment of the second foreclosure sale covering Valencia City properties.
They argued that the principal obligation was extinguished when PNB bought the Cagayan de Oro properties in the first foreclosure sale.
During pre-trial, the parties admitted to respective amounts:

Spouses Roque admitted indebtedness as of January 15, 2003, amounting to Php22,230,269.57.
PNB admitted its total bid of Php33,069,606.58.

PNB claimed it made a mistake in bidding for Valencia City properties and should have bid Php4,785,000.00 instead of Php16,534,803.29.
PNB sent a letter dated January 15, 2003, to correct the bid, but it was only received on August 5, 2003, after the certificate of sale had been issued.
PNB did not take any legal action to contest the second foreclosure sale.

On December 19, 2005, the trial court ruled both foreclosure sales valid and ordered PNB to return the excess proceeds amounting to Php10,839,337.01 plus legal interest.
PNB filed a Motion for Reconsideration on January 23, 2006, which was denied on May 3, 2006.
PNB received the denial on June 19, 2006, and filed a Notice of Appeal on June 27, 2006.
Respondents moved to disallow the appeal due to late filing and non-payment of appeal fees.
The trial court disallowed the appeal for failure to pay docket fees within the reglementary period.
PNB’s Motion for Reconsideration of the disallowance was also denied.

PNB filed a Petition for Certiorari before the CA under Rule 65 of the Rules of Court; the CA denied the petition.
PNB elevated the case to the Supreme Court through the Petition for Review on Certiorari.

Whether the rules on appeal, particularly the perfection of appeal concerning payment of docket fees, should be liberally construed considering petitioner’s alleged justifiable delay in payment.

Whether the subject foreclosure sale, specifically the second sale involving Valencia City properties, is valid despite PNB’s claimed mistake in bidding.

Whether the ruling of the trial court is inconsistent with the causes of action and prayer of the Spouses Roque in their complaint.