Title
Land Bank of the Philippines vs. Spouses De Jesus
Case
G.R. No. 221133
Decision Date
Jun 28, 2021
Spouses De Jesus sought to annul mortgages and prevent Land Bank from consolidating ownership, but their delay in pursuing a preliminary injunction led to abandonment. The Supreme Court upheld Land Bank's consolidation rights, ruling no due process violation and deeming the case moot.
due process
denial of motion
status quo order
A

Case Summary (G.R. No. 221133)

Factual Background

On September 17, 2009, Spouses Milu and Rosalina De Jesus filed a complaint in the RTC of Malolos seeking annulment of real estate mortgages, promissory notes and foreclosure sale, damages, and injunctive relief to prevent consolidation of title after a Certificate of Sale in favor of Land Bank of the Philippines had been issued and registered. The couple initially sought a Temporary Restraining Order; on September 23, 2009 they withdrew their TRO motion after counsel for Land Bank, Atty. Napoleon Latosa, orally committed in open court that the bank would not proceed with consolidation until the next hearing, and the RTC reset the matter as a hearing on preliminary injunction and the main case. The De Jesuses later moved to set the main case for pre-trial; multiple resets followed and the RTC scheduled the presentation of plaintiffs’ evidence on dates in 2012. On May 22, 2012 Land Bank filed an Entry of Appearance and Manifestation indicating its intent to consolidate title because the one-year redemption period had lapsed without redemption. The De Jesuses moved for a status quo order and for a hearing on their application for preliminary injunction; the RTC denied the status quo motion on August 22, 2012 and denied reconsideration on November 29, 2012.

Trial Court Proceedings

The RTC found that consolidation became a matter of right when the one-year redemption period expired without redemption, and that issuance of a status quo order would be tantamount to an injunction which, absent a hearing, the court could not grant. The RTC therefore denied the motion for issuance of a status quo order and proceeded to set or continue hearings on the merits. The De Jesuses sought reconsideration of the August 22, 2012 Order, which the RTC denied in its November 29, 2012 Order.

Court of Appeals Decision

The Court of Appeals granted the De Jesuses’ petition for certiorari and held that the RTC committed grave abuse of discretion by denying the motion for a status quo order without conducting a hearing on the application for preliminary injunction. The CA reasoned that the spouses should have been heard before Land Bank could consolidate title and remanded the case for immediate proceedings on the petitioners’ application for preliminary injunction. The CA denied Land Bank’s motion for reconsideration, finding no record support that the RTC construed the De Jesuses’ motion to set the case for pre-trial as abandonment of their injunction application, and concluding that the bank infringed the spouses’ right to procedural due process when it consolidated ownership prior to a final RTC ruling.

Parties’ Contentions on Petition

Land Bank of the Philippines maintained before the Court that the De Jesuses had abandoned their application for preliminary injunction by requesting pre-trial instead of proceeding with the scheduled hearing and by failing to move for the hearing for approximately two years, thereby demonstrating absence of the urgent necessity required for injunctive relief. The bank further argued that the CA’s remand amounted to an injunction-like restraint without hearing and thus violated the bank’s due process; it also asserted mootness given the consolidation it had effected. The Spouses De Jesus countered that their withdrawal of the TRO was conditioned on the bank’s commitment not to consolidate pending resolution of the main case and that the commitment therefore precluded consolidation for the duration of the main case; they also argued that a status quo order could be issued without a hearing and that the CA’s remand was proper.

Issue Presented

Whether the Court of Appeals erred in reversing the RTC’s August 22, 2012 and November 29, 2012 Orders on the ground of grave abuse of discretion amounting to lack or excess of jurisdiction.

Supreme Court Ruling

The Court granted Land Bank’s petition and held that the CA erred in reversing and setting aside the RTC’s orders. The Supreme Court reinstated the RTC’s August 22, 2012 and November 29, 2012 Orders and set aside the CA’s April 29, 2015 Decision and October 20, 2015 Resolution.

Legal Basis and Reasoning

The Court first reiterated the definition of grave abuse of discretion as an exercise of judgment so capricious or whimsical as to amount to lack or excess of jurisdiction, citing Ocampo v. Enriquez and related authorities. The Court found no such abuse by the RTC in denying the motion for a status quo order and declining to conduct the preliminary-injunction hearing when the plaintiffs manifested conduct inconsistent with the urgent character of injunctive relief. The record established that Atty. Latosa’s commitment was limited to not consolidating “up to the next hearing” and was made in the context of the TRO proceeding; the De Jesuses withdrew their TRO application precisely because of that limited commitment and the RTC scheduled the continuation of the presentation of evidence for the preliminary injunction. By subsequently moving to set the case for pre-trial instead of proceeding with the scheduled preliminary-injunction hearing, and by waiting approximately two years before moving for the hearing, the spouses manifested abandonment of their application for preliminary injunction and negated any showing of pressing necessity. The Court emphasized that a preliminary injunction is a preservative remedy invoked only when there is an urgent necessity to prevent injury that cannot be redressed by damages, citing Pahila-Garrido v. Tortogo and related jurisprudence, and that courts should not grant injunctive relief that effectively disposes of the main case without trial.

The Court further explained procedural requisites: Rule 58, Section 4 (d) mandates a summary

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