Title
Ramcar, Inc. vs. Hi-Power Marketing
Case
G.R. No. 157075
Decision Date
Jul 17, 2006
Bohol secured a loan from Ramcar, defaulted, and faced foreclosure. Courts ruled Bohol overpaid, nullifying the foreclosure and extinguishing his debt.

Case Digest (G.R. No. 157075)
Expanded Legal Reasoning Model

Facts:

  • Parties and Agreements
    • Ramcar, Incorporated (petitioner) and Leonidas D. Bohol with his wife and Hi-Power Marketing (respondents) are involved in a dispute over a loan and its secured payment.
    • Bohol acted as a distributor for Ramcar products in Quezon City and San Pablo City under the business name Hi-Power Marketing.
  • Loan and Mortgage Agreement
    • On March 4, 1982, Ramcar and Bohol entered into an agreement wherein:
      • Ramcar provided a P300,000.00 trade credit line for batteries.
      • Ramcar also released an additional P300,000.00 as a straight loan.
    • To secure the repayment:
      • Bohol executed a Real Estate Mortgage over a parcel of land (TCT No. 285976).
      • An undated promissory note was signed stating the payment schedule and breakdown of principal and interest.
  • Initiation of Foreclosure Procedures
    • Ramcar, claiming default on the loan by Bohol, petitioned the Quezon City sheriff for the foreclosure of the mortgage to satisfy an indebtedness of P370,429.42 plus accrued interest.
    • The auction sale was scheduled for July 6, 1984.
    • In response, on July 3, 1984, the Bohols filed a Petition for Prohibition with Preliminary Injunction (Special Civil Action No. Q-42032) before the RTC of Quezon City, Branch 101.
      • The RTC issued a status quo order on July 4, 1984, temporarily halting the auction sale.
      • Upon trial, the RTC dismissed the petition for prohibition on the ground of Bohol’s default.
  • Subsequent Litigation and Evidence
    • The Bohols filed motions for reconsideration and for new trial, which were denied on November 4, 1985.
    • They appealed the RTC decision to the Court of Appeals (CA) under CA-G.R. CV No. 11496.
    • While the appeal was pending, Ramcar, relying on the RTC’s dismissal, instructed the sheriff to proceed with the extrajudicial foreclosure.
      • Publication of the notice of sale in a newspaper for three consecutive weeks followed.
      • Despite the Bohols filing a separate case (Civil Case No. Q-46683) on November 28, 1985, seeking to declare the mortgage void on grounds of overpayment, the auction sale proceeded on November 29, 1985.
    • After the redemption period expired, Ramcar transferred the certificate of title into its name.
      • On February 11, 1987, TCT No. 354635 was issued in favor of Ramcar in place of the Bohols’ original TCT.
    • Ramcar later filed for a Writ of Possession on May 4, 1987 (LRC Case No. Q-3696), further consolidating the foreclosure proceedings with the other related cases.
  • Court of Appeals Intervention and Consolidation
    • On March 8, 1988, the Court of Appeals noted that the principal issue was whether the Bohols had defaulted on their loan payment.
      • The appellate court remanded the case to the RTC for a more thorough hearing on default, holding that Ramcar must prove both the fact and particulars of default.
      • The evidence submitted by both sides was insufficient to resolve the issue conclusively.
    • The three interrelated cases (Special Civil Action No. Q-42032, Civil Case No. Q-46683, and LRC Case No. Q-3696) were eventually consolidated before RTC Branch 101.
  • RTC and CA Decisions
    • After trial, on January 19, 1999, the RTC ruled in favor of Ramcar:
      • Finding Bohol had an outstanding unpaid obligation of P370,959.62.
      • Declaring the extrajudicial foreclosure valid and affirming the transfer of property.
    • On appeal (CA-G.R. SP No. 52593), the CA reversed the RTC decision:
      • Declaring that the Bohols’ payment records evidenced overpayment.
      • Setting aside the writ of possession, canceling Ramcar’s TCT No. 354635, and reinstating Bohol’s original TCT No. 285976.
      • Holding that the Bohols had not defaulted since their payments, properly evidenced, exceeded the amounts claimed by Ramcar.
  • Petition for Certiorari by Ramcar
    • On February 21, 2003, Ramcar filed a Petition for Certiorari with this higher court.
      • Alleging that the CA committed grave abuse of discretion by:
        • Refusing to consider its evidence indicating an outstanding balance.
        • Reversing the RTC order granting the writ of possession.
      • Arguing that alleged double crediting and wrong posting by the Bohols misrepresented their payment record.
    • The Bohols contended that:
      • The petition was an improper remedy.
      • The CA’s decision was correct based on the evidence submitted and on the proper application of the law.
    • The Court noted:
      • Ramcar did not demonstrate how the CA abused its discretion.
      • Ramcar’s evidentiary documents were not part of the record in the lower courts and were not properly authenticated.
      • Ramcar had an available appeal but failed to resort to it within the required period, rendering the CA decision final and executory.

Issues:

  • Whether the Bohols were in default at the time Ramcar proceeded with the extrajudicial foreclosure.
    • The central question: Did Bohol’s payment records, including evidence of overpayment, preclude the finding of default?
    • Whether the computations and documentary evidence presented by the Bohols were properly considered to demonstrate full satisfaction of the debt.
  • Whether the extrajudicial foreclosure was legally valid.
    • Based on whether all legal requirements for foreclosure and auction sale were properly complied with by the sheriff.
    • Whether the notice of sale and related procedures followed the requirements for a valid extrajudicial foreclosure process.
  • Whether Ramcar committed procedural and evidentiary errors in its handling of the foreclosure proceedings.
    • The issue of double crediting and wrong posting as alleged by Ramcar.
    • The validity and admissibility of new documentary evidence submitted by Ramcar in the appellate and certiorari proceedings.
  • Whether the petition for certiorari is the appropriate remedy given the facts of the case.
    • Whether the petition can substitute the lost remedy of appeal.
    • Whether the petition improperly raises questions of fact which are generally not reviewable on certiorari.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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