Case Digest (G.R. No. 158597) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On October 27, 1997, Marcos and Susan Prieto initiated a lawsuit in the Regional Trial Court (RTC) of Bauang, La Union, against Far East Bank and Trust Company (FEBTC) and the Spouses Antonio and Monette Prieto. The purpose of the suit was to declare null the real estate mortgage contracts executed using their property as collateral for loans totaling P5,000,000. Marcos and Susan had previously executed a Special Power of Attorney (SPA) in January 1996 that authorized Antonio to secure loans from FEBTC against their property located in Calumbaya, Bauang, covered by Transfer Certificate of Title No. T-40223. It was alleged that the mortgages obtained were exclusively in the name of Antonio and Monette, who had defaulted on the loans, prompting FEBTC to schedule an extra-judicial foreclosure set for October 31, 1997. The RTC initially granted a temporary restraining order (TRO) but later dismissed the case on July 31, 2001, asserting that Marcos could not claim any right against t Case Digest (G.R. No. 158597) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
Antecedents:
- On October 27, 1997, Spouses Marcos V. Prieto (Marcos) and Susan M. Prieto filed a complaint in the Regional Trial Court (RTC) of Bauang, La Union, against Far East Bank and Trust Company (FEBTC) and Spouses Antonio Prieto (Antonio) and Monette Prieto. The complaint sought to declare the nullity of several real estate mortgage contracts.
Special Power of Attorney (SPA):
- In January 1996, Marcos executed a Special Power of Attorney (SPA) authorizing Antonio to borrow money from FEBTC, using their real property in Calumbaya, Bauang, La Union, as collateral. The property was covered by Transfer Certificate of Title (TCT) No. T-40223.
Loans and Mortgages:
- Using the property as collateral, Antonio obtained a series of loans totaling P5,000,000.00 from FEBTC, evidenced by promissory notes and secured by separate real estate mortgage contracts. The loans were in the name of Antonio and Monette Prieto, not Marcos.
Failure to Pay and Foreclosure:
- Antonio and Monette failed to pay the loans, leading FEBTC to initiate extra-judicial foreclosure of the mortgages. The foreclosure sale was scheduled for October 31, 1997.
RTC Proceedings:
- The RTC issued a temporary restraining order (TRO) and later denied the application for a writ of preliminary injunction on March 24, 1998. The RTC eventually dismissed the complaint on July 31, 2001, ruling that Marcos had ratified Antonio's actions through a letter of acknowledgment dated September 12, 1996.
Appeal and Denial:
- Marcos filed a motion for reconsideration, which was denied on November 19, 2001. He filed a notice of appeal on November 26, 2001, which was denied by the RTC for being four days late. Marcos then filed a petition for certiorari in the Court of Appeals (CA), which was dismissed on April 24, 2002. The CA denied his motion for reconsideration on April 9, 2003.
Issues:
- Whether the Court of Appeals erred in dismissing Marcos' petition for certiorari due to the late filing of his notice of appeal.
- Whether Marcos' ratification of Antonio's actions through the letter of acknowledgment made him liable for the loans and mortgages.
- Whether the absence of a signature from one of the CA justices rendered the CA's resolution null and void.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
- The Supreme Court affirmed the CA's resolution, ruling that Marcos' failure to perfect his appeal on time rendered the RTC's decision final and executory. The Court also held that Marcos had ratified Antonio's actions through the letter of acknowledgment, making him liable for the loans and mortgages. The Court further ruled that the absence of a signature from one of the CA justices did not render the resolution null and void.