Title
Anama vs. Citibank, N.A.
Case
G.R. No. 192048
Decision Date
Dec 13, 2017
Anama sought to revive a 1982 CA judgment against Citibank, but the Supreme Court ruled that the RTC, not the CA, has jurisdiction over revival actions, denying his petition.

Case Summary (G.R. No. 192048)

Relevant Dates and Procedural Posture

Key dates: promissory note executed November 10, 1972; default in payments beginning January 1974; Citibank’s complaint for sum of money and replevin filed November 13, 1974 (Civil Case No. 95991); RTC replevin order issued December 2, 1974; motions and sheriff seizures in 1977; Anama’s certiorari/prohibition petition to the CA filed March 21, 1977; CA decision nullifying RTC seizure orders on July 30, 1982; Citibank’s petition to the Supreme Court filed August 25, 1982 and dismissed by the Supreme Court on March 17, 1999 with an Entry of Judgment on April 12, 1999. Records of the RTC were destroyed by fire on November 19, 1981; reconstruction proceedings were conducted in early 1982 and the RTC suspended incidents in December 1982 pending resolution of the Supreme Court case. Anama filed a petition for revival of judgment with the CA on March 12, 2009 (CA-G.R. SP No. 107748); the CA dismissed for lack of jurisdiction on November 19, 2009 and denied reconsideration April 20, 2010; the Supreme Court denied Anama’s Rule 45 petition on December 13, 2017, affirming the CA.

Factual Background

Anama obtained a loan from Citibank and executed a promissory note for P418,000 on November 10, 1972, and a chattel mortgage covering various industrial machineries and equipment located on his Quezon City property to secure repayment. Anama failed to pay monthly installments beginning January 1974. He asserted defenses and counterclaims alleging Citibank’s refusal to accept his checks and asserted defects in the chattel mortgage. The RTC found default and issued an order of replevin; subsequent enforcement efforts by sheriff and motions for alias writ of seizure led to the contested seizure and dismantling of machineries, which formed the basis of Anama’s CA petition for certiorari and prohibition.

Prior Court Rulings

The CA in CA-G.R. SP No. 06499 (July 30, 1982) granted Anama’s petition for certiorari and prohibition and declared the RTC’s February 28, 1977 and March 18, 1977 resolutions and consequential writs void ab initio. The CA ordered the return of the seized machineries to their original positions at respondents’ expense, repairs to destroyed concrete foundations and affected electrical wiring, and made permanent the writ of preliminary injunction. Citibank’s appeal to the Supreme Court (G.R. No. 61508) was dismissed on March 17, 1999, affirming the CA decision, with an Entry of Judgment filed April 12, 1999.

Record Loss and Suspension of Proceedings

During pendency of the CA petition, the fourth floor of Manila City Hall—housing RTC Branch 11 and the records of Civil Case No. 95991—was destroyed by fire on November 19, 1981. Anama successfully petitioned for reconstruction of the record in the RTC (petition filed February 10, 1982; reconstruction order granted May 3, 1982). With the Supreme Court petition pending, the RTC, on December 2, 1982, ordered suspension of all pending incidents in Civil Case No. 95991 until resolution of G.R. No. 61508.

Petition for Revival of Judgment and Relief Sought

On March 12, 2009, Anama filed a petition for revival of judgment with the CA to revive the CA’s July 30, 1982 decision and to obtain remand of Civil Case No. 95991 to the RTC for further proceedings, including disposition of Anama’s counterclaims. Anama argued that Citibank’s failure to institute reconstitution proceedings in the RTC constituted abandonment of its cause of action and of the complaint, thereby justifying revival and enforcement of the CA judgment and remand.

Respondent’s Contentions and CA Ruling on Jurisdiction

Citibank argued the CA lacked jurisdiction over a petition for revival of judgment because actions for revival fall within the exclusive original jurisdiction of the RTC; it also raised laches, contending Anama slept on his rights for nearly a decade, and denied abandonment of its money claim. The CA dismissed Anama’s petition for lack of jurisdiction (November 19, 2009), reasoning that actions to revive a judgment are properly cognizable by the RTC where the subject of litigation is incapable of pecuniary estimation or not within exclusive jurisdiction of any other forum, and that the CA did not have original authority to entertain such a revival action.

Legal Issues Presented to the Supreme Court

Primary issue: whether the CA had jurisdiction to entertain Anama’s petition to revive the CA’s earlier judgment, or whether jurisdiction over revival actions is exclusive to the RTC. Secondary matters raised—abandonment of claim by Citibank and laches—were treated but not decided as the jurisdictional question was dispositive.

Applicable Law and Foundational Legal Principles

  • Section 6, Rule 39, Revised Rules of Court: a final and executory judgment may be executed by motion within five years from entry; after five years and before barred by statute of limitations, it may be enforced by action; revived judgment may be enforced by motion within five years or thereafter by action.
  • Principle that a revival suit is a new and independent action whose cause of action is the judgment itself and not the merits of the original case; hence, the rules on commencement and jurisdiction of actions apply.
  • Jurisdiction rules: subject matter jurisdiction is conferred by law and determined by the nature of the action as pleaded; the statute in force at the commencement of the action determines jurisdiction.
  • BP 129 (Judiciary Reorganization Act of 1980), as amended by RA 7691, Section 19 confers exclusive original jurisdiction to RTCs over civil actions in which the subject of the litigation is incapable of pecuniary estimation. BP 129 Section 9 enumerates the CA’s original and appellate jurisdictions and does not include original jurisdiction over revival actions.

Supreme Court’s Analysis on Revival Actions and Jurisdiction

The Supreme Court affirmed the CA’s decision, reasoning that an action to revive a judgment is a new action with its cause of action being the final and executory decision itself. Because the relief sought in a revival action is to enforce a judgment—not to recover a sum of money alone—the primary issue is not a pecuniary claim but enforcement of non-pecuniary rights attendant to the judgment, rendering the subject matter “incapable of pecuniary estimation” for jurisdictional purposes under BP 129. Jurisdiction in such new actions therefore falls within the RTC’s exclusive original jurisdiction. The Court emphasized the distinction between jurisdiction and venue—citing Aldeguer v. Gemelo as an inapposite authority because that case concerned venue, not jurisdiction—and reiterated that jurisdiction cannot be conferred by consent

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