Case Digest (G.R. No. 160053)
Facts:
- Petitioners: Renato and Angelina Lantin.
- Entered into peso and dollar loan agreements with Planters Development Bank.
- Executed multiple real estate mortgages and promissory notes as security for the loans.
- Unable to meet payment obligations, leading the bank to initiate foreclosure proceedings.
- Mortgaged properties sold at public auction, with the bank as the winning bidder.
- On November 8, 2003, the Lantins filed a complaint in the RTC of Lipa City, Batangas.
- Sought declaration of nullity/annulment of the sale/mortgage, reconveyance, discharge of mortgage, accounting, permanent injunction, and damages.
- Argued that mortgages applied only to peso loans, which they claimed were fully paid.
- Bank filed a motion to dismiss, citing a stipulation in the loan agreements requiring legal actions to be filed in Metro Manila.
- RTC dismissed the case on May 15, 2003, for improper venue.
- Motion for reconsideration was denied, maintaining dismissal was based on procedural grounds.
Issue:
- (Unlock)
Ruling:
- The Supreme Court dismissed the petition by the Lantins.
- Affirmed RTC orders dated May 15, 2003, and September 15, 2003.
- Found no grave abuse of discretion in the dismissal for improper ve...(Unlock)
Ratio:
- Under Section 4(b) of Rule 4 of the 1997 Rules of Civil Procedure, parties can agree on an exclusive venue before initiating an action.
- Loan agreements specified that legal actions must be filed exclusively in Metro Manila, indicating a legitimate venue restriction.
- Terms like "exclusively...continue reading
Case Digest (G.R. No. 160053)
Facts:
The case involves petitioners Renato and Angelina Lantin, who took out several peso and dollar loans from the Planters Development Bank, leading to the execution of multiple real estate mortgages and promissory notes to secure these loans. Due to their failure to make payments, the bank initiated foreclosure proceedings on the mortgaged properties. The properties were subsequently sold at a public auction, with the bank emerging as the winning bidder. On November 8, 2003, the Lantins filed a complaint against the bank and its officers—Elizabeth Umali, Alice Perce, and Jelen Mosca—seeking a declaration of nullity and/or annulment of the sale, reconveyance, discharge of mortgage, accounting, permanent injunction, and damages in the Regional Trial Court (RTC) of Lipa City, Batangas. The petitioners contended that the mortgages only covered their peso loans, which they claimed had been fully paid, and thus should be discharged. They argued that the foreclosure was invalid as it pertained to their dollar loans, which were not covered by the mortgages. The private respondents moved to dismiss the complaint, citing improper venue based on a stipulation in the loan agreements that designated Metro Manila as the exclusive venue for any legal actions. On May 15, 2003, the RTC dismissed the case for improper venue. The petitioners sought reconsideration, arguing that the trial court had prejudged the validity of the loan documents by relying on the venue stipulation. The ...