Case Digest (G.R. No. 237506)
Facts:
San Miguel Corporation v. Leonara Francisco Vda. De Trinidad, et al., G.R. No. 237506, July 28, 2020, Supreme Court First Division, Reyes, J., writing for the Court. Petitioner San Miguel Corporation (SMC) challenged the Court of Appeals' (CA) affirmation of the Regional Trial Court's (RTC) voiding of real estate mortgages (REMs) and the consequent extrajudicial foreclosure over certain Las Piñas properties owned by respondents Leonara Francisco Vda. de Trinidad, Teodorico F. Trinidad, Gemma Trinidad‑Gandionco, Manuel F. Trinidad, and Grace F. Trinidad (collectively, Trinidad, et al.).Respondent Roberto N. Gandionco (Roberto) was a dealer with SMC and, to comply with SMC’s collateral requirement for dealership stock, he obtained from Gemma and the other registered owners several specially worded special powers of attorney (SPAs) authorizing him “to offer as collateral, security or property bond with [SMC]” particular titled parcels. The owners repeatedly delivered the original owner’s duplicate Transfer Certificates of Title (TCTs) to Roberto over several occasions. Using the SPAs and the duplicates, Roberto executed and registered REMs over two of the parcels in favor of SMC and obtained beer stocks from SMC.
Roberto subsequently issued successive post‑dated checks that were dishonored, leaving an alleged debt of about P7,000,000.00. SMC proceeded with extrajudicial foreclosure; SMC emerged as the highest bidder. Upon learning of the REMs and foreclosure, Gemma and Trinidad, et al. revoked the SPAs, notified SMC, and filed a complaint for annulment of mortgage and foreclosure sale and recovery of titles. Roberto did not answer and was declared in default.
On August 28, 2014, the RTC voided the REMs and foreclosures for lack of authority on Roberto’s part, ordered SMC to return the owner’s duplicate TCTs, and awarded moral damages, attorney’s fees, and costs. The RTC also dismissed SMC’s cross‑claim against Roberto for failure of proof.
SMC appealed to the CA. In its Decision dated October 10, 2017 (and Resolution dated February 14, 2018), the CA denied the appeal, holding that the SPAs must be strictly construed and that “to offer” did not include authority to mortgage; it therefor...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in affirming the trial court’s ruling that the SPAs did not include authority to mortgage the subject properties?
- Did the Court of Appeals err in denying SMC’s cross‑claims against Roberto Gandionco, despite his default, under Section 3 of Rule 9 o...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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