Case Digest (G.R. No. 176260) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Lucia Barrameda Vda. de Ballesteros v. Rural Bank of Canaman, Inc., petitioner Lucia Barrameda Vda. de Ballesteros (Lucia) sued her eight children and the Rural Bank of Canaman, Inc. (RBCI), represented by the Philippine Deposit Insurance Corporation (PDIC) as liquidator, in Civil Case No. IR-3128 before the Regional Trial Court of Iriga City (RTC-Iriga). On March 17, 2000, Lucia sought annulment of an extrajudicial partition and waiver of her late husband’s estate, annulment of a mortgage over Parcel B of the estate, and damages with prayer for preliminary injunction. She alleged that on March 6, 1995, her children, without her knowledge or consent, executed a partition agreement assigning both 357-square-meter lots in San Nicolas, Baao, Camarines Sur, to Rico Ballesteros, who then mortgaged Parcel B to RBCI. Lucia claimed occupancy of Parcel B as her only residence and prayed that the partition and mortgage be declared null and void. In its answer, RBCI asserted that Lucia Case Digest (G.R. No. 176260) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Original Complaint
- On March 17, 2000, petitioner Lucia Barrameda Vda. de Ballesteros filed Civil Case No. IR-3128 before the RTC-Iriga, Branch 36, for the annulment of an extrajudicial partition and deed of mortgage, damages, and preliminary injunction against her eight children (Roy, Rito, Amy, Arabel, Rico, Abe, Ponce Rex, Adden) and the Rural Bank of Canaman, Inc. (RBCI).
- She alleged that her husband left two 357-sqm parcels in San Nicolas, Baao, Camarines Sur; that on March 6, 1995, her children partitioned both parcels to Rico Ballesteros without her knowledge or consent; that Rico mortgaged Parcel B to RBCI and faced foreclosure; and that she occupied Parcel B with no other home.
- RBCI’s Answer and PDIC Receivership
- RBCI answered that Lucia sold her share (one parcel) to Rico in 1979; that partition and mortgage were made with her knowledge, albeit unsigned; and that Parcel B was foreclosed and auctioned in 1999. Attorney’s fees were claimed as a counterclaim.
- In January 2001, RBCI was closed and placed under PDIC receivership; PDIC lawyers took over the defense on February 4, 2002.
- Jurisdictional Challenge, RTC-Iriga Dismissal, and CA Consolidation
- On May 9, 2003, PDIC moved to dismiss for lack of jurisdiction, invoking Section 30 of R.A. 7653 (New Central Bank Act), which designated RTC-Makati, Branch 59, as the liquidation court for RBCI.
- On July 29, 2003, RTC-Iriga granted the motion and dismissed Civil Case No. IR-3128 without prejudice, directing Lucia to file her claim before the liquidation court.
- Lucia appealed to the CA, which on August 15, 2006 set aside the dismissal and ordered the consolidation of Civil Case No. IR-3128 with Special Proceeding No. M-5290 (liquidation case) before RTC-Makati. A motion for reconsideration was denied on December 14, 2006. Lucia then filed a petition for review on certiorari under Rule 45.
Issues:
- Whether the RTC-Iriga, Branch 36, retained jurisdiction to continue and finally decide Civil Case No. IR-3128 despite the creation of a liquidation court.
- Whether the Court of Appeals erred or gravely abused its discretion in ordering the consolidation of Civil Case No. IR-3128 with Special Proceeding No. M-5290 before RTC-Makati, Branch 59.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)