Case Digest (G.R. No. 213054) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 2001, Simon Lori Holdings, Inc. (SLHI), Fortunato G. Pe, Raymundo G. Pe, Jovencio F. Cinco, and Jose Revilla Reyes, Jr. (collectively, respondents) extended a ₱50,000,000 loan to Dante Tan, facilitated by PentaCapital Investment Corporation and secured by Dante’s shares in Best World Resources Corporation. When Dante defaulted at maturity and vanished, respondents filed a collection suit before the Makati RTC (Civil Case No. 01-357). On May 21, 2002, the Makati RTC rendered judgment in respondents’ favor for ₱100,100,000 plus interest, attorney’s fees, and costs. A Writ of Execution issued in February 2005 led Deputy Sheriff Rommel Ignacio to levy on a titled parcel (TCT No. 126981) registered in Dante’s name. After a March 29, 2005 auction and the lapse of the redemption period, a Sheriff’s Final Deed of Sale in favor of respondents was recorded. Dante’s omnibus motion to quash the writ and to declare the conjugal property exempt was denied and became final. On May 2, 2007, Case Digest (G.R. No. 213054) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Loan Transaction and Collection Case
- In 2001, Simon Lori Holdings, Inc., PentaCapital Investment Corporation, and individual lenders extended a ₱50,000,000 loan to Dante Tan, secured by his Best World Resources Corporation shares.
- Dante defaulted; respondents filed Civil Case No. 01-357 in Makati RTC Branch 146. On May 21, 2002, the court ordered Dante to pay ₱100,100,000 plus interest, attorney’s fees, and costs.
- Execution Proceedings
- A Writ of Execution was issued on February 16, 2005; Deputy Sheriff levied on Dante’s Parañaque property under TCT No. 126981 and auctioned it on March 29, 2005.
- Sheriffs Final Deed of Sale was issued in favor of respondents. Dante’s omnibus motion claiming the property as family home and conjugal partnership was denied and became final.
- Nullification Case in Parañaque RTC
- On May 2, 2007, Teresita Tan filed Civil Case No. 07-0134 in Parañaque RTC to nullify the auction sale and cancel the certificate of sale.
- The RTC first dismissed the case for res judicata (July 8, 2010), then on reconsideration (January 6, 2011) reversed itself and nullified the auction sale, certificate, and Final Deed of Sale. Respondents’ reconsideration motion was denied on April 27, 2011.
- Appeal Attempts and CA Proceedings
- Respondents filed a Motion for Extension (June 2, 2011), then withdrew it and filed a late Notice of Appeal on June 17, 2011; Parañaque RTC denied the appeal on August 5 and October 17, 2011.
- Respondents petitioned the Court of Appeals via certiorari. On January 22, 2013, the CA granted the petition and directed allowance of the late appeal; its resolution denying reconsideration was issued June 11, 2014.
Issues:
- Jurisdiction and Judicial Stability
- Whether the Parañaque RTC violated the doctrine of judicial stability by entertaining Teresita Tan’s nullification case and nullifying the auction sale, despite the Makati RTC’s exclusive authority over execution proceedings.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)