Title
Supreme Court
Spouses Ibasco vs. Private Development Corp. of the Philippines
Case
G.R. No. 162473
Decision Date
Oct 12, 2009
A borrower defaulted on a loan secured by mortgaged land, sued to halt foreclosure, and claimed damages due to alleged loan release delays. Courts upheld the mortgage's validity, denied injunctive relief, and ruled the appeal untimely, affirming the lender's right to foreclose.

Case Digest (G.R. No. 162473)
Expanded Legal Reasoning Model

Facts:

  • Background of the Transaction
    • In 1980, petitioner Santiago E. Ibasco obtained a loan of P600,000 from respondent Private Development Corporation of the Philippines (PDCP) to finance his business.
    • The loan was secured by four parcels of land located in Camarines Norte, which were mortgaged to PDCP under a mortgage contract dated 15 October 1980 and supplemented on 15 April 1982.
  • Default and Extrajudicial Foreclosure
    • Ibasco defaulted on his loan payments, and by November 1984 the debt had increased to P1,077,515.58.
    • On 23 November 1984, PDCP initiated collection of its security by filing a petition for extrajudicial foreclosure of the mortgage with the Camarines Norte Provincial Sheriff.
  • Filing of the Lawsuit for Injunctive Relief and Damages
    • Petitioners, composed of Santiago E. Ibasco, his wife Milagros Ibasco, and Prime Feeds, Inc. (an assignee of one of the mortgaged lands), brought a suit in the Regional Trial Court of Daet, Camarines Norte, Branch 38.
    • The complaint sought an injunction to halt the foreclosure proceedings and damages against PDCP, contending that a delay in the release of the loan proceeds by PDCP led to the failure of Ibasco’s business.
  • Procedural History at the Lower Courts
    • The trial court initially issued a temporary restraining order to halt the foreclosure proceedings but later dismissed the complaint on 27 April 1994 for lack of merit, finding that PDCP had released the loan on time and that the petitioners’ claim for damages was baseless.
    • Petitioners appealed the dismissal to the Court of Appeals, which affirmed the trial court’s decision in its ruling dated 23 December 2003.
  • Motion for Reconsideration
    • Petitioners filed a motion for reconsideration; however, the motion was filed on 1 March 2004, which was 20 days beyond the allowable period considering they received the decision on 26 January 2004 (with the deadline being 10 February 2004).
    • The Court of Appeals denied the motion for reconsideration in its Resolution dated 12 March 2004.

Issues:

  • Timeliness and Procedural Bar in Filing the Motion for Reconsideration
    • Whether the petitioners’ motion for reconsideration, being filed 20 days past the prescribed deadline, is procedurally valid.
    • Whether the finality of the Court of Appeals’ decision precludes review due to the lapse of the period allowed for reconsideration.
  • Merits of the Claim for Injunctive Relief
    • Whether petitioners have established their entitlement to an injunction restraining PDCP from foreclosing on the mortgaged properties.
    • Whether the contention that delays in the release of loan proceeds constitute grounds for nullifying the mortgage contract and justifying injunctive relief is legally tenable.
  • Validity and Effect of the Mortgage and Underlying Loan Contract
    • Whether the mortgage agreement, as an accessory contract deriving its validity from the principal loan agreement, can be annulled solely on the argument of alleged delay in the release of loan proceeds.
    • Whether any delay alleged by petitioners affects the enforceability of the underlying loan contract and the subsequent foreclosure process.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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