G.R. No. 148444 - Associated Bank vs. Spouses Pronstroller

The petitioner, Associated Bank (now United Overseas Bank Phils.), filed a Motion for Reconsideration.
The Court found that the motion did not raise new issues and merely reiterated previously discussed arguments.
The arguments presented were deemed unmeritorious, consistent with the findings in the July 14, 2008 Decision.
The Court emphasized that the second letter-agreement modified the first agreement, which was executed by Atty. Jose Soluta, Jr.
Atty. Soluta was granted apparent authority to modify the initial agreement due to the lack of a board resolution explicitly authorizing him.

Respondents had requested a modification of the earlier agreement in June 1993, seeking full payment upon the Court's decision confirming the bank's rights to the property.
The Board of Directors deferred action on this request for a year and ultimately rejected it after the bank's reorganization.
The Court noted that respondents could reasonably believe that the second letter-agreement signed by Atty. Soluta was a response to their request.

The Court clarified that the first letter-agreement was not rescinded due to respondents' failure to deposit full payment, as the payment date had been modified by the second agreement.
The second letter-agreement was also not rescinded by respondents' new offer, which was intended to demonstrate their capacity to purchase the property.

The Court affirmed the factual findings of the Court of Appeals, which were well-supported by evidence.
It reiterated the principle that if no error is shown in the appreciation of facts by the appellate court, those findings are treated as conclusive.
The legal conclusions drawn by the appellate court were deemed accurate and convincing.

Spouses Eduardo and Ma. Pilar Vaca filed a Motion for Leave to Intervene, claiming to be the registered owners of the subject property and asserting their right to be heard.
They argued that they would be deprived of their family home without due process and sought reimbursement from the petitioner.

The Court denied the Motion for Leave to Intervene, citing Section 2, Rule 19 of the Rules of Court, which allows intervention only before the rendition of judgment.
The spouses Vaca's motion was considered belated, as they were not strangers to the action but rather transferees of the property during the litigation.
Their legal interest arose from the sale of the property by the petitioner, making them successors-in-interest.

The applicable provision for transfers of interest is Section 19, Rule 3 of the Rules of Court, which allows the original party to continue the action unless the court orders otherwise.
The Court referenced previous rulings indicating that a transferee pendente lite does not have the right to intervene, as they are bound by the proceedings and judgments affecting their predecessor-in-interest.