Case Summary (G.R. No. 221133)
Antecedents
On September 17, 2009, spouses De Jesus initiated a legal action against Land Bank, seeking the annulment of real estate mortgages and promissory notes in favor of Land Bank, along with a temporary restraining order (TRO) to prevent impending foreclosure foreclosure. This situation was underscored by the issuance and registration of a Certificate of Sale favoring Land Bank, heightening the urgency for the spouses De Jesus to take legal action.
Initial Proceedings in Regional Trial Court
The Regional Trial Court (RTC) set a hearing for the TRO application for September 23, 2009. Following the initial presentation of evidence by spouses De Jesus, they withdrew their TRO application based on a commitment from Atty. Napoleon Latosa, the bank's counsel, not to consolidate ownership during the hearing on the preliminary injunction. The RTC then proceeded with the case, scheduling further hearings.
Subsequent Hearings and Delays
Throughout subsequent months, the case faced several delays, including the untimely demise of Atty. Latosa and the rescheduling of hearings. The RTC conducted a preliminary conference in 2011 and set dates for the presentation of evidence in 2012. Meanwhile, in May 2012, Land Bank communicated its intent to proceed with ownership consolidation due to the expiration of the one-year redemption period without any action from the De Jesus spouses.
RTC’s Ruling
On August 22, 2012, the RTC denied the motion for a status quo order to maintain the bank's non-consolidation while ruling that Land Bank had the right to consolidate ownership due to the expiration of the redemption period. The court further articulated that an order for status quo would essentially function as an injunction, which could not be granted without a hearing.
Court of Appeals Ruling
The Court of Appeals (CA) reversed the RTC's orders, citing a grave abuse of discretion by the RTC for denying the motion for a status quo order without conducting a hearing. The CA emphasized that spouses De Jesus should be heard before consolidation of ownership occurs.
Reconsideration and CA’s Response
Land Bank moved for reconsideration, arguing that spouses De Jesus had abandoned their application for a preliminary injunction due to their motion for a pre-trial and the inordinate delay in pushing for an injunction hearing. The CA denied the motion, highlighting the procedural due process violated by the consolidation of ownership before a hearing could take place.
Land Bank’s Arguments
In its petition to the Supreme Court, Land Bank asserted that the CA erred by reversing the RTC's orders. It claimed that spouses De Jesus’s actions demonstrated abandonment of their injunction application, thus undermining their claims of urgency and necessity for relief.
Supreme Court's Ruling
The Supreme Court affirmed the RTC's rulings, concluding that the RTC did not manifest grave abuse of discretion.
...continue readingCase Syllabus (G.R. No. 221133)
Case Overview
- This case involves a Petition for Review on Certiorari filed by the Land Bank of the Philippines (petitioner) against Spouses Milu and Rosalina De Jesus (respondents).
- The petition seeks to contest the April 29, 2015 Decision and the October 20, 2015 Resolution of the Court of Appeals (CA) in CA-G.R. SP No. 128480.
Antecedents
- On September 17, 2009, the spouses De Jesus filed a Complaint for Annulment of Real Estate Mortgage, Promissory Note and Foreclosure Sale and Damages, including an Urgent Application for a Temporary Restraining Order (TRO) and/or Writ of Preliminary Injunction against Land Bank.
- The Complaint prayed for the nullity of the real estate mortgages and promissory notes executed in favor of Land Bank and sought to prevent the bank from consolidating ownership over the properties, as a Certificate of Sale had already been issued and registered.
Proceedings in the Regional Trial Court (RTC)
- The RTC set a hearing for the application for TRO on September 23, 2009, during which the spouses De Jesus presented their first witness.
- Following the presentation, the spouses withdrew their motion for a TRO due to a commitment from Land Bank’s counsel not to consolidate ownership during the hearing on the preliminary injunction.
- Subsequent hearings scheduled for October 28, 2009, were postponed at the request of the spouses. The RTC later ordered a pre-trial conference in lieu of the preliminary injunction hearing.
- The RTC conducted a preliminary conference on July 19, 2011, and set dates for the presentation of the couple's evidence in June and August 2012.
- On May 22, 2012, La