Case Digest (G.R. No. 172302) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On July 9, 2004, Pryce Corporation filed a petition for corporate rehabilitation with the Regional Trial Court of Makati, Branch 138, alleging serious financial distress and attaching a rehabilitation plan. On July 13, 2004, the court, finding the petition sufficient in form and substance under the Interim Rules of Procedure on Corporate Rehabilitation, issued an ex parte stay order and appointed Gener T. Mendoza as rehabilitation receiver. On September 13, 2004, the court gave due course to the petition and directed the receiver to evaluate Pryce’s proposed plan. Finding it inadequate, the receiver submitted an amended plan, which the court approved on January 17, 2005. This order outlined asset disposals, liability liquidation through dacion en pago, waiver of accrued penalties, an interest freeze as of July 13, 2004, and currency conversion terms. China Banking Corporation and the Bank of the Philippine Islands (BPI), creditors of Pryce, separately appealed to the Court of Ap Case Digest (G.R. No. 172302) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petition and rehabilitation proceedings
- Pryce Corporation filed a petition for corporate rehabilitation on July 9, 2004 with the Regional Trial Court (RTC) of Makati, Branch 138.
- On July 13, 2004, the RTC found the petition sufficient in form and substance, issued a stay order and appointed Gener T. Mendoza as Rehabilitation Receiver.
- Approval of rehabilitation plan
- On September 13, 2004, the RTC gave due course to the petition and directed the Receiver to evaluate Pryce’s proposed plan.
- The Receiver submitted an amended rehabilitation plan, which the RTC approved by order dated January 17, 2005, identifying assets for disposition and the method of liability liquidation.
- Appeals and Supreme Court referrals
- China Banking Corporation and Bank of the Philippine Islands (BPI) separately appealed to the Court of Appeals (CA):
- The 7th Division granted China Bank’s petition (July 28, 2005) and set aside the RTC’s orders.
- The 1st Division initially granted BPI’s petition, then on reconsideration dismissed it; BPI’s Supreme Court petition (G.R. No. 180316) was denied with finality (Jan 30 2008).
- Pryce’s appeal to the Supreme Court (SC) first division was denied on February 4, 2008 with a remand to RTC; motions for reconsideration were denied (June 16, 2008) and the case was referred En Banc (June 22, 2009). A stay of proceedings (Aug 6, 2013) expired without settlement, leading to resolution of Pryce’s second motion for reconsideration.
Issues:
- Whether the validity of the RTC’s January 17, 2005 rehabilitation order is res judicata in light of BPI v. Pryce Corporation (G.R. No. 180316).
- Whether the rehabilitation court was required to hold a hearing under the “serious situations” test (Rizal Commercial Banking Corp. v. IAC) before issuing the stay order under Rule 4, Section 6 of the Interim Rules on corporate rehabilitation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)