G.R. No. 215999 - Spouses Chua vs. United Coconut Planters Bank

The parties entered into a Joint Venture Agreement (JVA) for property development, where petitioners (including Spouses Chua and co‑petitioners) and their various co‑owners agreed to develop properties for commercial and residential purposes.
Under the JVA, petitioners transferred parcels of land to Revere Realty and Development Corporation, a company controlled by respondent Jose C. Go, via deeds of absolute sale and complemented by two deeds of trust executed on April 30, 1998.
The deeds of trust confirmed that the petitioners remained the true and absolute owners despite the transfer, as the properties were held “in trust.”

On March 21, 2000, petitioners (Spouses Chua and LGCTI) and respondent United Coconut Planters Bank (UCPB) entered into a Memorandum of Agreement (MOA) to consolidate petitioners’ obligations as of November 30, 1999 amounting to approximately ₱204.6 million.
As part of the MOA implementation, petitioners executed a Real Estate Mortgage (REM) over 26 parcels while UCPB and Revere executed another REM involving 18 parcels on the same day.
UCPB waived certain penalties and interests and agreed to convert a balance of ₱68 million into equity interest in LGCTI through a subsequent deed of assignment.

UCPB foreclosed on the REMs, selling the properties for a total bid price of approximately ₱227.7 million, with separate breakdowns for petitioners’ REM and the Revere REM.
Petitioners, alleging wrongful application of foreclosure proceeds and non‑compliance with their directions (including requests for an accounting and re‑appraisal), filed a complaint in the Regional Trial Court (RTC) in February 2004.
The RTC issued a writ of preliminary injunction, declared certain defendants in default, and rendered a partial judgment in September 2005 declaring:

The deeds of trust were valid and the properties were held "in trust" for petitioners.
Defendants Revere and Jose C. Go had no authority over the properties, ordering their reconveyance.
Monetary awards for moral damages and attorney’s fees were imposed.

The RTC subsequently modified its partial judgment clarifying that the reconveyance issue did not extend to UCPB and that further resolution on UCPB’s obligations was to be determined after the presentation of full evidence.
UCPB later foreclosed the REMs and applied the foreclosure proceeds toward the consolidated loans, though petitioners protested the application especially regarding the inclusion of the Revere REM properties and application against obligations allegedly unrelated to them.

On January 6, 2009, the RTC rendered a final judgment in favor of petitioners, which was later reversed by the Court of Appeals (CA) on grounds including the validity of the 1997 REM and the Revere REM.
Petitioners elevated the case to the Supreme Court, which in its August 16, 2017 decision reinstated the RTC judgment with modifications.
The decision declared:

The consolidated obligations under the MOA were fully paid upon proper application of the foreclosure proceeds.
The deeds of trust were valid and the properties were held in trust, thereby nullifying the Revere REM.
Orders for UCPB to execute deeds of reconveyance for certain properties and to return the excess proceeds were issued.
Specific monetary awards and interest charges were imposed against UCPB.

Subsequent motions for reconsideration by respondents (UCPB, Asset Pool A, Revere, and Jose C. Go) and motions to inhibit or refer the case to the Court en banc were filed, raising both procedural and substantive challenges.

Whether petitioners’ consent was properly given for the execution of the Revere REM, considering that similar instruments were executed concurrently with the MOA.
Whether the Revere REM should be declared valid or null and void in view of the trust documents and lack of direct signatures from petitioners.

Whether the MOA’s consolidation of obligations (only naming the petitioners as borrowers) precluded the inclusion of a separate debt of respondent Jose Go.
Whether UCPB’s application of foreclosure proceeds first to extinguish petitioners’ debt and then toward alleged third‑party obligations was proper.

Whether there was a procedural due process violation in the prompt promulgation of the August 16, 2017 decision, given the timing relative to the appointment of certain Supreme Court members.
Whether the motions for inhibition and for referral to the Court en banc were properly raised, considering the absence of established bias or grounds under the applicable rules.

Whether UCPB should be ordered to return excess foreclosure proceeds to petitioners, including the computation of such surplus.
Whether the imposition of legal, compensatory, moral, and exemplary damages as well as attorney’s fees against UCPB was properly supported by the record.