Case Digest (G.R. No. 234196)
Facts:
In Spouses Francis N. Celones and Felicisima Celones v. Metropolitan Bank and Trust Company and Atty. Crisolito O. Dionido, the petitioners, the Spouses Celones together with their corporation, Processing Partners and Packaging Corporation (PPPC), secured various loans from Metrobank totaling ₱64,474,058.73, pledging multiple real properties as collateral. After default, Metrobank foreclosed and was declared winning bidder in July 2007, initiating a one-year redemption period and filing writs of possession in several trial courts. Before redemption lapsed, Spouses Celones sought to pay ₱55 million pursuant to a Conditional Notice of Approval for Redemption dated December 13, 2007. To finance this, they engaged Atty. Dionido, who advanced the ₱55 million via two manager’s checks. On December 20, 2007, Metrobank, PPPC, the Celones, and Dionido executed a Memorandum of Agreement (MOA) providing that Dionido would subrogate Metrobank’s rights and interests over the loan obligation aCase Digest (G.R. No. 234196)
Facts:
- Background loans and foreclosures
- Spouses Francis N. Celones and Felicisima Celones, together with their company Processing Partners and Packaging Corporation (PPPC), obtained various loans from Metrobank, mortgaging several properties. The total obligation amounted to ₱64,474,058.73.
- The Spouses defaulted, prompting Metrobank to foreclose all mortgaged properties. Metrobank was the winning bidder at the foreclosure sale (Certificates of Sale issued July 2007) and filed petitions for writs of possession before several courts.
- Redemption efforts and execution of MOA
- Before the one‐year redemption period expired, Spouses Celones offered to redeem. Metrobank issued a Conditional Notice of Approval for Redemption (CNAR) dated December 13, 2007, approving their offer of ₱55 Million, payable on or before December 20, 2007.
- To raise the ₱55 Million, the Spouses secured a loan from Atty. Crisolito O. Dionido, who issued two manager’s checks (₱35 Million and ₱20 Million).
- On December 20, 2007, Metrobank, PPPC, Spouses Celones, and Atty. Dionido executed a Memorandum of Agreement (MOA) whereby Dionido would pay Metrobank ₱55 Million and, in consideration, be subrogated to all of Metrobank’s rights and interests over the loan obligation and the foreclosed properties.
- Upon receipt of the checks, Metrobank issued payment slips in the Spouses’ names and caused the dismissal of its writ‐of‐possession petitions.
- Metrobank declined to issue Certificates of Redemption to the Spouses, asserting that all rights had been transferred to Dionido; Dionido then sent demand letters for possession upon alleged lapse of the redemption period.
- The Spouses filed a complaint for declaratory relief and injunction. On September 1, 2010, the RTC declared the MOA without force and effect, held that the Spouses had redeemed the properties, ordered Metrobank to issue Certificates of Redemption and deliver titles, and made the injunction permanent.
- The Court of Appeals, in a Decision dated April 14, 2014, reversed the RTC: it declared the MOA a valid contract of subrogation entitling Dionido to Metrobank’s rights, directed the Spouses to surrender possession, and ordered them to pay Dionido and Metrobank various sums for loans, damages, and attorneys’ fees. The CA denied reconsideration on December 11, 2014.
Issues:
- Whether Spouses Francis N. Celones and Felicisima Celones redeemed the foreclosed properties from Metrobank using the loan from Atty. Crisolito O. Dionido.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)