Case Digest (G.R. No. 159912)
Facts:
In G.R. No. 159912, decided on August 17, 2007 under the 1987 Constitution, United Coconut Planters Bank (UCPB) filed a Petition for Review on Certiorari under Rule 45 to annul the Court of Appeals’ January 21, 2003 Decision and September 9, 2003 Resolution in CA-G.R. CV No. 67318. Those rulings had affirmed the Regional Trial Court (RTC), Branch 65, Makati City, Civil Case No. 99-314 Decision of March 23, 2000 and Order of May 8, 2000, which declared void the interest-rate provisions in the promissory notes executed by spouses Samuel and Odette Beluso in favor of UCPB. On April 16, 1996, UCPB granted the Belusos a credit line of ₱1.2 million under a Credit Agreement, later amended to increase the line to ₱2.35 million and extend maturity to February 28, 1998. The spouses issued three promissory notes for ₱700,000, ₱500,000, and ₱800,000, all renewed several times. On April 30, 1997, the last two notes were debited to their account and a consolidated ₱1.3 million note was issuedCase Digest (G.R. No. 159912)
Facts:
- Parties and Background
- Petitioners: United Coconut Planters Bank (UCPB) granted Spouses Samuel and Odette Beluso a promissory‐note credit line under a Credit Agreement (initially up to ₱1.2 M, term to April 30, 1997; later amended to ₱2.35 M, term to February 28, 1998).
- Security: Real estate mortgage over parcels in Roxas City (TCT Nos. T-31539, T-27828) and promissory notes.
- Promissory Notes and Drawdowns
- Original Notes:
- PN 8314-96-00083-3 (₱700,000; 29 Apr 1996 – 27 Aug 1996)
- PN 8314-96-00085-0 (₱500,000; 2 May 1996 – 30 Aug 1996)
- PN 8314-96-000292-2 (₱800,000; 20 Nov 1996 – 20 Mar 1997)
- Renewals and Further Advances:
- Consolidated ₱1.3 M note (due 28 Feb 1998) after debiting two notes on 30 Apr 1997.
- Two additional notes (₱200,000 and ₱150,000; 11 Dec 1997 and 2 Jan 1998 – both due 28 Feb 1998), allegedly never credited by Belusos.
- Interest Charges, Payments, Demand, and Foreclosure
- UCPB charged rates from 18% to 34%; Belusos paid ₱763,692.03 (1996–Feb 1998).
- Post‐maturity charges (Feb 28 1998–Jun 10 1998): compounded interest (28–33%) and penalties (30–36%) on ₱2.35 M.
- 2 Sept 1998: UCPB demanded ₱2,932,543 + 25% attorney’s fees; no payment.
- 28 Dec 1998: Bank foreclosed mortgaged properties; indebtedness ballooned to ₱3,784,603.
- Trial Court Proceedings (RTC Makati, Civil Case No. 99-314)
- 9 Feb 1999: Belusos filed Petition for Annulment, Accounting, and Damages.
- 23 Mar 2000 Decision:
- Void interest‐rate provision and foreclosure; order to return properties.
- UCPB to pay Belusos ₱50,000 attorney’s fees and costs.
- Belusos to pay UCPB ₱1,560,308.
- 8 May 2000: RTC denied UCPB’s Motion for Reconsideration.
- Court of Appeals Proceedings (CA-G.R. CV No. 67318)
- 21 Jan 2003 Decision: Affirmed RTC decision but removed bank’s liability for attorney’s fees/costs.
- 9 Sept 2003 Resolution: Denied UCPB’s Motion for Reconsideration.
- Petition for Review
Issues:
- Whether the CA erred in affirming the voiding of the agreed interest‐rate provision.
- Whether the CA erred in upholding the RTC’s computation of indebtedness (₱1,560,308).
- Whether the CA erred in annulling the foreclosure due to “incorrect computation.”
- Whether the CA erred in finding UCPB liable under the Truth in Lending Act.
- Whether the CA erred in not dismissing the case for alleged forum shopping.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)