Case Digest (G.R. No. 207004) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Astrid A. Van de Brug, Martin G. Aguilar and Glenn G. Aguilar vs. Philippine National Bank (G.R. No. 207004, June 6, 2018), the late spouses Romulus and Evelyn Aguilar obtained sugar crop loans from the Philippine National Bank (PNB) Victoria Branch between the late 1970s and early 1980s, secured by four parcels of land in Negros Occidental. Upon their failure to pay, PNB foreclosed the mortgage in 1985 and acquired title to the properties. After Republic Act No. 7202 (Sugar Restitution Law) took effect on February 29, 1992, Romulus wrote PNB in 1995 seeking recomputation under the new law. Evelyn received a letter in 1997 from PNB requiring submission of ten-year crop records, agreement to the audited computation, and implementation of restructuring. The Aguilars allegedly complied and received COA-audited statements showing a total obligation of ₱2,236,337.91 as of November 30, 1999. Two agricultural lots were conveyed via voluntary offer to sell (VOS) to the Department of Case Digest (G.R. No. 207004) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Parties
- Petitioners Astrid A. van de Brug, Martin G. Aguilar, and Glenn G. Aguilar (children and heirs of the late spouses Romulus and Evelyn Aguilar) filed a Rule 45 petition assailing:
- The CA Decision (March 23, 2012) in CA-G.R. CV No. 00708 reversing the RTC.
- The CA Resolution (April 1, 2013) denying their motion for reconsideration.
- Respondent Philippine National Bank (PNB) foreclosed the sugar crop loans of the late spouses Aguilar, consolidating four mortgaged parcels (one residential, three agricultural) under its name.
- RA 7202 and Pre-Litigation Correspondence
- Republic Act No. 7202 (Sugar Restitution Law) was approved on February 29, 1992 to restitute sugar producers’ losses from Crop Years 1974–1975 to 1984–1985.
- July 5, 1995 – Romulus Aguilar requested PNB to reconsider his foreclosed account under RA 7202.
- September 17, 1997 – PNB replied to Evelyn Aguilar, requiring her to:
- Implement account restructuring within 60 days.
- Signify conformity to PNB’s recomputation.
- Submit ten-year crop production data (1974/1975–1984/1985).
- Statements of Account and VOS of Agricultural Lands
- COA-audited Statement of Account (as of December 15, 1996) and latest as of November 30, 1999 reflected total dues of ₱2,236,337.91 (RA 7202 and non-RA 7202 accounts).
- PNB made a Voluntary Offer to Sell (VOS) agricultural Lots No. 3749 and 3587 to DAR, with LBP valuations totaling ₱3,212,012.48 (December 1998 & November 1999).
- Letters by Heirs and Filing of Complaint
- February–April 2000 – Glenn Aguilar wrote PNB requesting RA 7202 benefits, citing the analogous Pfleider case.
- September 22, 2000 – PNB advised that having acquired the properties by foreclosure, it could convey them to DAR without owing any excess proceeds to the Aguilars.
- January 3, 2001 – Aguilars filed a complaint to implement RA 7202, claiming moral/exemplary damages, attorney’s fees, litigation expenses. PNB answered, denied cause of action (for non-compliance) and counterclaimed for damages.
- RTC Decision and CA Ruling
- RTC Decision (December 10, 2004):
- Dismissed PNB’s counterclaim.
- Ordered PNB to accord RA 7202 benefits, credit VOS proceeds to account, amortize any shortfall over 13 years, and reconvey the residential lot; awarded damages and attorney’s fees.
- CA Decision (March 23, 2012):
- Held the Aguilars’ loans qualified under RA 7202 but COA-audited recomputation showed no excess payment.
- Deemed foreclosure as full payment per IRR Section 6; denied restitution; dismissed complaint.
- CA Resolution (April 1, 2013) denied reconsideration. Petitioners elevated the case to the Supreme Court.
Issues:
- Main Issue
- Whether the CA erred in excluding sums received by PNB from DAR’s payment (CARP proceeds) of the Aguilars’ foreclosed agricultural lands when computing RA 7202 benefits.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)