Title
Supreme Court
Gutang vs. Deputy Sheriff, Regional Trial Court, Branch 22, Manila
Case
G.R. No. 119716
Decision Date
Jul 31, 2007
A dispute over Mandaluyong property involving conflicting claims from public auctions and a superior mortgage lien by FGU Insurance, upheld by the Supreme Court.

Case Summary (G.R. No. 119716)

Background of the Case

On April 22, 1977, Looyuko and Uy initiated a complaint for a sum of money against Tomas Mendoza, leading to the issuance of a writ of preliminary attachment over the aforementioned property. Concurrently, Gutang also filed a complaint against Tomas Mendoza in Iloilo City's Court of First Instance, which culminated in a decision favoring Gutang on December 24, 1980. Following this, the property was sold at a public auction to Gutang on October 4, 1984, after no redemption occurred.

Title Consolidation and Liens

After the property was levied upon and sold to Gutang, a final certificate of sale was issued on November 15, 1985, which resulted in the cancellation of the original TCT and the issuance of a new title (TCT No. 242) in Gutang's name. It is essential to note that TCT No. 242 retained all liens previously annotated on TCT No. (450666)-1702, including a mortgage in favor of FGU Insurance Corporation.

Subsequent Proceedings

On March 4, 1986, the Manila RTC ruled in favor of Looyuko and Uy in their case against Tomas Mendoza, and a writ of execution was subsequently issued. The property was again levied upon and sold at public auction to the private respondents on May 8, 1986. The certificate of sale was issued on December 20, 1990, and later motions led to the cancellation of TCT No. 242 and the issuance of TCT No. 10107 in the names of Looyuko and Uy.

Controversy Over Jurisdiction and Title Cancellation

Gutang contested the authority of the Manila RTC to cancel her title and to issue a new title to the private respondents. Despite appealing the RTC's order, Gutang's appeal was dismissed by the Court of Appeals. The petitioner subsequently filed this petition for review, asserting that the RTC lacked jurisdiction.

Foreclosure Proceedings and Liens

A significant development occurred when FGU Insurance Corporation initiated foreclosure proceedings based on its mortgage recorded prior to Gutang's and the private respondents' claims. The Supreme Court addressed the validity of these proceedings and concluded that the liens of FGU Insurance Corporation took precedence over those of Gutang and the private respondents.

Summary of Judicial Findings

The Supreme Court affirmed the view that Gutang and the private respondents acquired the property subject to the existing encumbrances, and they essentially purchased their equity of redemption. The Court articulated tha

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