G.R. No. 136100 - Uy vs. Land Bank of the Philippines

Land Bank of the Philippines (Land Bank) filed a complaint for unlawful detainer against Felipe G. Uy before the Metropolitan Trial Circuit Court (MTCC) of Iloilo City on February 24, 1988.
Land Bank claimed ownership of two parcels of land located in Quezon Street, Iloilo City, with a two-story house thereon, seeking to eject Uy as occupant.

The properties were originally owned by Tia Yu.
Tia Yu authorized Gold Motors Parts Corporation to mortgage the properties as security for a loan from Land Bank.
On August 19, 1980, Gold Motors mortgaged the properties to Land Bank but defaulted on the loan.
Land Bank initiated foreclosure proceedings and became the highest bidder at the foreclosure sale, receiving a certificate of sale.
Titles to the properties were consolidated under Land Bank's name in October 1986 (TCT No. T-73490 and TCT No. T-73491).

Uy claimed he furnished materials to build the house but Tia Yu failed to fully pay for them.
In February 1980, Uy and Tia Yu agreed that Uy would occupy the house and apply rent toward the P400,000 balance debt.
Their agreement was later formalized in a Lease Contract dated June 6, 1982.

The MTCC favored Uy, concluding Land Bank was aware of the lease at mortgage constitution and accepted the mortgage subject to the lease's terms.
The MTCC dismissed Land Bank’s complaint, confirmed Uy’s possession rights per the Lease Contract, and awarded attorney’s fees and litigation expenses to Uy.

RTC affirmed the MTCC decision in full.
The RTC remarked that the mortgage was void under Article 2085 of the Civil Code (mortgagor must be absolute owner), but this was not included in the dispositive portion.
The RTC upheld that Land Bank could not claim possession against Uy.

Land Bank filed a motion for extension to file a petition for review on certiorari to the CA on December 12, 1996, citing late receipt of case records, incomplete documents, and limited time.
CA granted a 15-day extension only (until December 27, 1996).
Land Bank failed to file within the extension but submitted its petition on January 11, 1997, 15 days late.

The respondent (Uy) filed a motion to dismiss citing untimeliness.
CA initially denied Land Bank’s petition for untimeliness but later, on February 20, 1997, admitted the petition.
On July 1, 1998, CA reversed the RTC decision, ruling that Land Bank held superior title and possession rights.
CA held that the MTCC and RTC erred in declaring the mortgage void and that the validity of the mortgage was not a matter in the unlawful detainer case.
Both parties’ motions for reconsideration were denied by CA.

Felipe Uy filed a petition to review the CA decision.
The SC initially denied the petition for (a) lack of certification against forum shopping and (b) lack of verification.
Petitioner later filed motions seeking admission of verification and certification, accepted by the SC after reconsideration.
The SC reinstated the petition and required comments from respondent.

Whether the Court of Appeals erred in admitting Land Bank’s petition for review despite late filing beyond the extension granted.
Whether the RT Court erred in declaring the mortgage between Gold Motors and Land Bank void for lack of absolute ownership.
Whether Land Bank has a superior right to possession over the subject properties compared to petitioner Uy, considering the existing lease agreement.
Whether the lease agreement between petitioner and Tia Yu is binding on Land Bank, the purchaser at the foreclosure sale.
Whether the issuance of Transfer Certificates of Title in favor of Land Bank negates the lessee's rights under Article 1676 of the Civil Code.