Case Summary (G.R. No. 229339)
Relevant Legal Framework
This case is primarily governed by the provisions of the 1987 Philippine Constitution, given that the decision was rendered in 2019, alongside pertinent aspects of the Civil Code that regulate contract interpretation, reformation, and mutual mistakes.
Factual Background
On May 19, 2006, Globe Asiatique and Union Bank executed a MOA which allowed Union Bank to purchase accounts receivable stemming from Globe Asiatique's condominium sales. Subsequently, Globe Asiatique executed DAs and SPAs, transferring rights, titles, and interests over the units to Union Bank. In November 2011, Globe Asiatique sought the reformation of these agreements, claiming that they did not reflect the true intent of the parties and were the result of mutual mistakes. Union Bank denied this assertion, maintaining that the agreements were correct and complete and sought dismissal of the reformation complaint.
Legal Proceedings
On September 27, 2012, Globe Asiatique initiated a civil action for reformation. Following a pre-trial, Globe Asiatique filed a Motion for Summary Judgment on June 4, 2014, which Union Bank opposed on June 20, 2014. The Regional Trial Court (RTC) denied the motion for summary judgment on grounds of genuine issues of material fact, highlighting conflicting allegations necessitating a full trial.
Ruling of the RTC
The RTC's refusal to grant summary judgment was based on its assessment that there were material factual discrepancies between the parties’ accounts, requiring a trial to resolve such issues. Globe Asiatique's motion for reconsideration was subsequently denied, affirming the need for a deeper judicial examination.
Court of Appeals' Decision
On July 13, 2016, the Court of Appeals (CA) affirmed the RTC's ruling, determining that no grave abuse of discretion was present in the RTC’s denial of the motion for summary judgment. The CA noted the necessity of evidence presentation to resolve factual disputes surrounding the claims of mutual mistake and the true intent of the parties under the executed DAs and SPAs.
Issue on Appeal
The principal issue in contention is whether the CA erred in concluding that the RTC did not commit grave abuse of discretion in denying Globe Asiatique’s motion for summary judgment, especially given the alleged admissions made by Union Bank during the proceedings.
Supreme Court’s Ruling
The Supreme Court reiterated that a motion for summary judgment should only be granted when there are no ge
...continue readingCase Syllabus (G.R. No. 229339)
Case Overview
- This case involves a Petition for Review on Certiorari filed by Globe Asiatique Realty Holdings Corporation (hereafter referred to as "Globe Asiatique") against Union Bank of the Philippines (hereafter referred to as "Union Bank").
- The petition seeks to reverse and set aside the Decision dated July 13, 2016, and the Resolution dated January 5, 2017, of the Court of Appeals (CA) in CA-G.R. SP No. 141501.
- The main contention revolves around the denial of Globe Asiatique's Motion for Summary Judgment by the Regional Trial Court (RTC) of Pasig City, which was affirmed by the CA.
Parties Involved
- Petitioner: Globe Asiatique Realty Holdings Corporation
- Engaged in real estate development and sales, particularly condominium units.
- Respondent: Union Bank of the Philippines
- Financial institution that entered into a Memorandum of Agreement with Globe Asiatique regarding the purchase of accounts receivables.
Factual Background
- On May 19, 2006, Globe Asiatique and Union Bank entered into a Memorandum of Agreement (MOA) for the purchase of installment accounts receivables arising from Globe Asiatique’s sales of real estate units.
- Between October 30, 2006, and May 30, 2007, Globe Asiatique executed 10 Deeds of Assignments (DAs) and 11 Special Powers of Attorney (SPAs) in favor of Union Bank covering 10 condominium units in GA Tower 1.
- The DAs indicated an absolute transfer of rights and interests in the properties, while the SPAs provided Union Bank with various powers concerning the contracts with homebuyers.
- On November 17, 2011, Globe Asiatique requested a reformation of these documents, asserting that they did not reflect the true agreement