Case Summary (G.R. No. 163117)
Background and Procedural History
EPCIB extended several loans to the respondents from 1998 to 2000, totaling P26,200,000. These loans were documented through several promissory notes and secured by real estate mortgages on multiple parcels of land. After the respondents defaulted on these loans, EPCIB initiated extra-judicial foreclosure proceedings against the mortgaged properties. In response, the respondents filed a complaint for annulment of the mortgages and sought a temporary restraining order to halt the foreclosure.
Trial Court Proceedings
On December 16, 2002, the trial court granted a temporary restraining order that temporarily prevented the foreclosure sale. Following a hearing, the trial court issued a writ of preliminary injunction on January 28, 2003, which maintained the injunction against the foreclosures until the case was resolved. EPCIB's subsequent motions for reconsideration were denied, prompting EPCIB to file a petition for certiorari with the Court of Appeals.
Court of Appeals' Ruling
The Court of Appeals dismissed EPCIB's certiorari petition, asserting that the trial court did not act with grave abuse of discretion in issuing the injunction. The appellate court characterized the order as interlocutory, which generally cannot be subject to immediate appeal. Instead, the court noted that EPCIB should have addressed these issues in a subsequent appeal of the main case rather than through certiorari.
Core Legal Issue
EPCIB contended that the Court of Appeals erred in dismissing its petition for certiorari, arguing that the trial court's actions constituted grave abuse of discretion amounting to lack of jurisdiction. EPCIB asserted that the injunction was improperly issued, given that there was no legal or factual basis presented by the respondents to warrant such injunctive relief.
Supreme Court Decision
The Supreme Court ruled in favor of EPCIB, emphasizing that while interlocutory orders typically are not appealable, they may be questioned if issued with grave abuse of discretion. The Court found that the lower court failed to establish the respondents’ clear legal rights, given their acknowledgment of debt and clear default. The C
...continue readingCase Syllabus (G.R. No. 163117)
The Case
- This case involves a petition for review of the Court of Appeals' Resolutions dated October 29, 2003, and April 1, 2004.
- The petitioner is Equitable PCI Bank, Inc. (EPCIB), and the respondents are Maria Leticia Fernandez and Alice Sison Vda. de Fernandez.
- The Court of Appeals dismissed EPCIB's petition for certiorari, affirming the Regional Trial Court's (RTC) order granting a writ of preliminary injunction in favor of the respondents.
The Facts
- Between 1998 and 2000, EPCIB extended loans to the respondents totaling P26,200,000, secured by real estate mortgages on five parcels of land.
- The loans were evidenced by several promissory notes executed by the respondents.
- After the loans matured and went unpaid, EPCIB filed for an extra-judicial foreclosure of the mortgaged properties on October 22, 2002.
- Respondents filed a complaint on December 11, 2002, for annulment of the mortgages and sought a temporary restraining order (TRO) against EPCIB and the sheriff.
- On December 16, 2002, the RTC issued a 20-day TRO to prevent the foreclosure sale, with a hearing for a preliminary injunction set for January 6, 2003.
- The RTC issued a writ of preliminary injunction on January 28, 2003, preventing the foreclosure until the case was resolved.
- EPCIB's motion for reconsideratio