Case Summary (G.R. No. 164547)
Court Proceedings and Background
Petitioner CGP obtained two loans totaling Sixteen Million Pesos from Respondent PCI, secured by real estate mortgages over two parcels of land located in Muntinlupa City. Due to non-payment by CGP, PCI initiated extra-judicial foreclosure, during which PCI emerged as the highest bidder in a public auction. Subsequently, PCI sought a writ of possession to obtain actual control of the property, which led to CGP contesting the request based on a pending Civil Case that involved an annulment of the foreclosure proceedings.
Orders by the RTC and Motions for Reconsideration
Initially, on 15 November 2000, the RTC issued an order allowing PCI to seek a writ of possession, stating that such requests do not require a hearing when there's a foreclosure. CGP filed a Motion for Reconsideration, asserting that the proceedings violated a preliminary injunction from an earlier case involving the same parties. On 27 March 2001, the RTC granted CGP's motion, effectively nullifying the ex-parte proceedings, and reinstating the injunction, leading PCI to subsequently file a Motion for Reconsideration.
RTC's Order and Judicial Interpretation
In its order dated 30 August 2001, the RTC reiterated the need for a hearing involving both parties before granting the writ. Furthermore, it recognized the complexities introduced by overlapping cases and motions, highlighting issues that warranted due process considerations. The RTC rejected ex-parte proceedings based on CGP's verified opposition and the earlier injunction, determining that a hearing was necessary before any further action could be taken regarding PCI's request.
PCA's Petition for Certiorari and Court of Appeals' Decision
Displeased with the RTC's orders, PCI filed a petition for certiorari under Rule 65, alleging that the RTC had acted with grave abuse of discretion. The Court of Appeals, in its decision dated 26 March 2004, granted PCI’s petition, asserting that the RTC had improperly suspended proceedings in a case unrelated to the writ of possession. The Court of Appeals ruled that any issues regarding the validity of the mortgage did not preclude the granting of possession, as the foreclosure had already been validly completed.
Allegations of Procedural Errors and Issues of Fact
CGP’s subsequent petition, which contested the Court of Appeals' ruling, emphasized that factual issues were involved and disputed the appellate court's authority to determine those issues, referencing a previous resolution which indicated a factual basis was at play. CGP argued that the appellate court had erred in entertaining PCI’s petition for certiorari.
Supreme Court's Ruling on the Nature of Appeals
The Supreme Court, while affirming the Court of Appeals
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Case Overview
- The case involves a Petition for Review on Certiorari filed under Rule 45 of the Revised Rules of Court.
- It seeks to annul and set aside the Decisions dated 26 March 2004 and 13 July 2004 of the Court of Appeals in CA G.R. SP No. 68528.
- The initial case was between PCI Leasing and Finance, Inc. (petitioner in the lower court) and CGP Transportation and Services Corporation (respondent in the lower court).
Background Facts
- Petitioner CGP obtained two loans from respondent PCI, amounting to P16,000,000.00, secured by real estate mortgages over two parcels of land located in Bo. Cupang, Muntinlupa City.
- CGP defaulted on the loans, prompting PCI to initiate extra-judicial foreclosure proceedings.
- PCI emerged as the highest bidder during the public auction, leading to the issuance of Certificates of Sale, which were registered on 19 November 1997.
- CGP failed to redeem the properties within the redemption period, leading PCI to demand actual possession.
RTC Proceedings
- On 12 April 1999, PCI filed a petition for ex-parte issuance of a Writ of Possession with the Regional Trial Court (RTC) of Muntinlupa City, which CGP opposed.
- On 15 November 2000, the RTC ruled against CGP, stating the law allowed PCI to petition for a Writ of Possession during the redemption period.
- CGP filed a Motion for Reconsideration, asserting that an existing preliminary injunction against the foreclosure proceedings rendered the RTC's order invalid.
RTC Orders and Reconsiderations
- On 27 March 2001, the RTC granted CGP's Motion for Reconsideration, nullifying the ex-parte proceedings and reinstating the