Title
Spouses Cacayorin vs. Armed Forces and Police Mutual Benefit Association, Inc.
Case
G.R. No. 171298
Decision Date
Apr 15, 2013
Spouses Cacayorin sought consignation of loan payment after Pag-IBIG loan failed; SC ruled RTC, not HLURB, had jurisdiction.

Case Digest (G.R. No. 171298)
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)

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