Case Digest (G.R. No. 171298) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Oscar and Thelma Cacayorin v. Armed Forces and Police Mutual Benefit Association, Inc., petitioners Oscar and Thelma Cacayorin sought to purchase Lot 5, Block 8, Phase I of Kalikasan Mutual Homes in San Pedro, Puerto Princesa City, through a loan facilitated by the Rural Bank of San Teodoro under Pag-IBIG. On July 4, 1994, the parties executed a Loan and Mortgage Agreement, followed by the Rural Bank’s letter of guaranty to AFPMBAI for ₱77,418.00, leading AFPMBAI to issue a Deed of Absolute Sale and a new Transfer Certificate of Title No. 37017 in the petitioners’ names with the mortgage annotated. The Pag-IBIG loan never materialized, the Rural Bank closed and was placed under PDIC receivership, and AFPMBAI came into possession of the loan documents and the title. Unable to determine the proper payee, petitioners filed Civil Case No. 3812 for consignation of payment, recovery of title, and cancellation of the mortgage annotation. The RTC of Puerto Princesa City denie... Case Digest (G.R. No. 171298) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and contractual relations
- Petitioners Spouses Oscar and Thelma Cacayorin purchased Lot 5, Block 8, Phase I, Kalikasan Mutual Homes, San Pedro, Puerto Princesa City, from respondent AFPMBAI through a housing loan facility.
- On July 4, 1994, petitioners and the Rural Bank of San Teodoro executed a Loan and Mortgage Agreement under Pag-IBIG’s Home Financing Program; loan proceeds of ₱77,418.00 were guaranteed for release upon title transfer and annotation of mortgage.
- Execution and title issuance
- By virtue of the Rural Bank’s August 22, 1994 letter of guaranty, AFPMBAI executed a Deed of Absolute Sale in favor of petitioners.
- Transfer Certificate of Title No. 37017 was issued in petitioners’ names with annotation of the mortgage under Entry No. 3364.
- Loan failure, receivership, and possession of documents
- The Pag-IBIG loan did not push through; the Rural Bank closed and was placed under receivership by PDIC.
- AFPMBAI obtained possession of petitioners’ loan documents and TCT No. 37017; petitioners failed to pay the remaining purchase price despite oral and written demands by AFPMBAI.
- Judicial proceedings
- In July 2003, petitioners filed Civil Case No. 3812 for consignation of payment, recovery of title, and cancellation of mortgage annotation, naming AFPMBAI, PDIC, and the Register of Deeds as defendants.
- AFPMBAI moved to dismiss for lack of jurisdiction (claiming HLURB jurisdiction under PD 957) and failure of prior tender; RTC denied the motion and declared PDIC in default; CA granted certiorari, set aside RTC orders, and held the HLURB to have exclusive jurisdiction; petitioners then filed this petition for review.
Issues:
- Whether Civil Case No. 3812 falls within the exclusive jurisdiction of the Housing and Land Use Regulatory Board under PD 957, or is a judicial consignation action exclusively cognizable by the Regional Trial Court.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)