Title
Spouses Yap vs. Spouses Dy
Case
G.R. No. 171868
Decision Date
Jul 27, 2011
Spouses sold mortgaged lands without bank consent, leading to foreclosure. Buyers redeemed some properties; court upheld partial redemption, nullified fraudulent sale, and awarded damages against the bank.

Case Digest (G.R. No. 171868)
Expanded Legal Reasoning Model

Facts:

  • Parties and Mortgages
    • Spouses Tirambulo–Estorco owned seven parcels (Lots 1, 3, 4, 5, 6, 8 under TCT Nos. T-14777, T-20301, T-14780, T-14794, T-14781, T-14783; and Lot 846 by tax decl.).
    • December 3, 1976: Mortgage of Lots 1, 4, 5, 6, 8 to Dumaguete Rural Bank, Inc. (DRBI) for ₱105,000; August 3, 1978: Mortgage of Lots 3 and 846 for ₱28,000.
    • October 27, 1979: Tirambulos sold all seven lots to Spouses Dy and Spouses Maxino without DRBI’s consent.
  • Foreclosure, Sale and Redemption Attempts
    • March 31, 1982: DRBI extrajudicially foreclosed the 1976 mortgage (Lots 1, 4, 5, 6, 8); DRBI was highest bidder at ₱216,040.93; Certificate of Sale registered June 24, 1983.
    • July 6, 1983: DRBI sold Lots 1, 3, 6 to Spouses Yap under Deed of Sale with Mortgage; Yaps secured writ of possession.
    • May 22–28, 1984: Dys and Maxinos tendered ₱40,000 to DRBI and Yaps; both refused. They consigned ₱50,625.29 with the sheriff for Lots 1, 6, 3; sheriff issued redemption certificate for Lots 1, 6 only, noting Lot 3 was not foreclosed.
  • Judicial Proceedings
    • June 1984: Dys and Maxinos filed Civil Case No. 8426 (accounting, nullity of sale of Lot 3, injunction, damages) and Case No. 8439 (consolidation, annulment of redemption, damages).
    • February 12, 1997: RTC ruled for Yaps; invalidated Dys/Maxinos’ redemption; confirmed Yaps’ title to Lots 1, 3, 6.
    • May 17, 2005: CA reversed RTC, held Lot 3 not foreclosed, validated Dys/Maxinos’ redemption of Lots 1, 6, nullified sale of Lot 3 to Yaps, awarded damages. March 15, 2006: CA denied possession restitution but affirmed damages.
    • SC review by Yaps and DRBI ensued.

Issues:

  • Whether Lot 3 was included in the 1982 foreclosure sale.
  • To whom redemption money must be paid.
  • Whether Dys and Maxinos validly redeemed Lots 1 and 6.
  • Whether DRBI is liable for damages to Dys and Maxinos.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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