G.R. No. 144882 - Briones-Vasquez vs. Court of Appeals

Case Digest (G.R. No. 144882)
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Facts:

Credit Facilities and Mortgage

Plast-Print Industries, Inc. (Plast-Print) applied for credit facilities from Rizal Commercial Banking Corporation (RCBC) consisting of:

Secured Term Loan – ₱6.65 M
Secured Loan Line – ₱4.49 M
Import/Domestic LC/TR Line – ₱2 M

Total principal ₱12.98 M. These were secured by a real estate mortgage over properties covered by TCT Nos. 499643, 617967, 597336, 597337, 621037, 59286 and PT-91458.

Plast-Print issued promissory notes (PN) Nos. 153-95, 185-95, 465-95, 514-95, 951-95, 1058-95. It defaulted on PNs Nos. 514-95, 951-95, 185-95, 465-95 and the LC/TR line. RCBC demanded payment (letter July 31, 1997) and sent statements of account. Plast-Print disputed three payments, reconciled accounts on October 9, 1997, but still failed to pay. It offered restructuring, issued two post-dated checks of ₱2 M each (one dishonored). RCBC’s written demand put its obligations at ₱13,452,372.85 as of October 10, 1997.

Extrajudicial Foreclosure and SEC Proceedings

RCBC filed petitions for extrajudicial foreclosure on May 4, 1998. On November 12, 1998, some mortgaged properties were auctioned, RCBC being highest bidder. A second auction was set November 30, 1998.
On October 5, 1998, unknown to RCBC, Plast-Print filed with the SEC a petition for suspension of payments. The SEC ordered a 30-day suspension on November 16, 1998, halting the second auction. Negotiations produced a Restructuring Agreement (June 25, 1999), approved by the SEC (July 22, 1999), under which Plast-Print acknowledged indebtedness to RCBC of ₱11,216,178.22 as of December 31, 1998, to be paid by December 31, 2004. Plast-Print later defaulted; its request for moratorium on August 21, 2000 was denied.

RTC Complaint and Appeals

On August 22, 2000, Plast-Print and its VP Dequito filed before RTC Antipolo (Branch 74, Civil Case No. 00-5875) a complaint for accounting, cancellation of the sheriff’s certificates of sale, injunction, and damages. They alleged ₱5,506,152.00 in uncredited payments and premature foreclosure.
RCBC moved to dismiss for lack of jurisdiction (pending SEC petition), defective certification against forum shopping, and prior judgment (SEC order). The RTC denied the motion of April 16, 2001. A certiorari petition to the CA was dismissed. In its Answer ad Cautelam, RCBC reiterated jurisdictional objections and raised estoppel and laches.
The RTC rendered judgment on May 17, 2006 in favor of Plast-Print and Dequito:

Declared the foreclosure sale null and void and ordered cancellation of the certificates of sale on TCTs Nos. 499643, 617967, 597336, 597337 and 621037;
Directed RCBC to make accounting and recomputation of payments;
Awarded ₱200,000.00 attorney’s fees and costs of suit.

RCBC appealed to the CA, assigning errors on jurisdiction, payment applications, forum shopping, prior judgment, and awards of fees. On May 31, 2011, the CA affirmed the RTC. Its Resolution denying reconsideration was issued November 9, 2011. RCBC filed this Rule 45 petition on January 2, 2012.

Issues:

Jurisdiction

Whether the CA erred in holding that the RTC had jurisdiction over Plast-Print’s complaint despite the pending SEC petition.

Accounting Relief

Whether the CA erred in directing RCBC to make an accounting and recomputation of Plast-Print’s payments.

Foreclosure Nullification

Whether the CA erred in affirming the cancellation of the foreclosure sale and certificates of sale.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Doctrine:

(Subscriber-Only)

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Case Digest (G.R. No. 144882)
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Case Digest (G.R. No. 144882)
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