Case Summary (G.R. No. 184068)
Applicable Law
The relevant legal framework for this case stems from the 1987 Philippine Constitution and the applicable provisions of civil law regarding obligations and contracts, particularly concerning compromise agreements and the authority of corporate officers.
Factual Background
EGI obtained a loan from PSBank amounting to Php 24,064,000.00, secured by a real estate mortgage on two properties. Despite a scheduled repayment plan, EGI defaulted after making only partial payments. As a result, PSBank invoked the acceleration clause in the promissory note and initiated extrajudicial foreclosure proceedings. EGI responded by filing a complaint for a writ of preliminary injunction and a restraining order against PSBank, leading to a compromise agreement approved by the trial court in January 1993. The agreement detailed EGI's acknowledgment of the loan and terms for full payment or transfer of property ownership to PSBank.
Further Proceedings and Compliance Issues
Despite the compromise agreement, EGI failed to comply with the terms of payment, prompting PSBank to seek enforcement through a motion for execution. The trial court's issuance of a writ of execution was later suspended for clarification, and upon re-evaluation, the court reinstated the writ, confirming PSBank's right to execute the compromise agreement. EGI contested the validity of the agreement, claiming that Santos lacked authority from the board of directors to enter into such an agreement.
Court of Appeals Ruling
The Court of Appeals (CA) annulled the trial court's orders that had declared the compromise agreement null and void, reinstating the trial court's decision from January 1993. The CA concluded that EGI had, in effect, empowered Santos through apparent authority based on prior dealings and lack of prompt objection to his actions. The CA held that EGI was estopped from contesting the authority of Santos due to the significant delay in raising such a defense, which constituted laches.
Supreme Court's Ruling
Upon appeal before the Supreme Court, EGI argued that the CA erred in reinstating the compromise agreement. However, the Supreme Court denied the petition, emphasizing that EGI's argument hinged on a factual determination regarding Santos' authority, which is typically beyond the scope of review in a Rule 45
...continue readingCase Syllabus (G.R. No. 184068)
The Case
- The case G.R. No. 187262 involves a petition filed by Engineering Geoscience, Inc. (EGI) against Philippine Savings Bank (PSBank).
- EGI challenges the Decision promulgated by the Court of Appeals (CA) on November 13, 2008, and the Resolution on March 19, 2009, which annulled prior Orders from the Regional Trial Court (RTC) in Civil Case No. Q-91-9150.
- The CA granted PSBank's petition for certiorari and prohibition, reinstating the RTC's Decision dated January 12, 1993.
The Facts
- The case has been before the CA twice, with a summary of events leading to PSBank's petition for certiorari and prohibition.
- EGI filed a Complaint With Prayer For Writ Of Preliminary Injunction and Restraining Order against PSBank, alleging issues with a loan contract.
- EGI secured a loan of Php24,064,000.00 from PSBank through a Promissory Note dated February 14, 1990, backed by a Real Estate Mortgage over two parcels of land.
- The repayment schedule included specific amounts due at set intervals, but EGI only made partial payments totaling Php3,223,192.91 before ceasing all further payments.
- PSBank invoked an acceleration clause and demanded full payment, leading to a petition for extra-judicial foreclosure of the mortgage, which was halted by EGI's injunction.
- A Compromise Agreement was reached on January 12, 1993, which set terms for settlement of EGI's obligations, including the payment of Php38,002,182.56 by December 31, 1993.
- EGI subsequently failed to comply with the terms of the compromise, prompting PSBank to seek a Writ of Execution.
- The RTC's