Title
Philippine National Bank Binalbagan Branch vs. Tad-y
Case
G.R. No. 214588
Decision Date
Sep 7, 2022
Spouses secured loans with REM; PNB failed to pay taxes, acquired properties at auction. Court ruled PNB breached contract, acted as attorney-in-fact, and must reconvey titles upon reimbursement.
A

Case Summary (G.R. No. 214588)

Procedural History

The Tad‑ys filed a complaint for breach of contract and reconveyance in the Regional Trial Court (RTC), Branch 55, Himamaylan City (Civil Case No. 912). The RTC rendered judgment ordering PNB to reconvey Lots 778 and 788 to the plaintiffs upon payment of the auction acquisition price plus expenses and 12% interest. PNB appealed to the Court of Appeals (CA), which affirmed the RTC’s decision. PNB’s motion for reconsideration in the CA was denied. PNB then filed a petition for review on certiorari to the Supreme Court, which denied the petition and affirmed the CA and RTC rulings.

Material Facts

  • On January 30, 1975, spouses Jose and Patricia Tad‑y obtained an agricultural sugar crop loan from PNB for P109,000, secured by a REM over six parcels in Himamaylan and Hinigaran. The REM was annotated on the titles.
  • On August 14, 1975, the spouses obtained a second agricultural loan (P63,000), which the REM was extended to cover and likewise annotated.
  • On August 9, 1988, Lots 778 and 788 (both covered by the REM) were sold at a provincial tax delinquency auction for unpaid real property taxes. PNB participated and was the sole bidder, acquiring both lots for a total price of P10,609.63. Final Bills of Sale issued on August 23, 1989, and the certificates of sale were annotated on the respective titles.
  • The Tad‑ys availed themselves of restructuring under RA 7202 in November 1995 and completed payments in 1996. On March 6, 1996, PNB executed a deed of release of the REM but excluded Lots 778 and 788, claiming ownership by virtue of the auction acquisition.
  • Patricia Tad‑y repeatedly requested release and offered reimbursement of the auction price (letters dated July 19, 2001 and October 23, 2003). PNB refused to reconvey but offered to negotiate repurchase.
  • The Tad‑ys filed their complaint on March 23, 2004. The RTC, and later the CA and Supreme Court, addressed whether PNB breached the REM, whether PNB’s auction purchase inured to the benefit of the Tad‑ys by virtue of agency under the REM, whether the action was barred by prescription or laches, and whether a constructive trust arose.

Issues Presented

  1. Whether PNB breached the REM by failing to pay real property taxes on Lots 778 and 788.
  2. Whether PNB’s acquisition of the lots at the tax delinquency auction was attributable to PNB acting as attorney‑in‑fact (agent) of the spouses under paragraph (d) of the REM and thus inured to the benefit of the Tad‑ys.
  3. Whether the Tad‑ys’ action was barred by prescription or laches and whether PNB may raise prescription for the first time on appeal.

RTC’s Findings and Relief

The RTC held that: (a) the REM’s paragraph (c) (last sentence) obligated the mortgagee to advance taxes and insurance premiums if the mortgagor failed to pay; by not paying taxes, PNB refused to perform and allowed delinquency, then participated in and acquired the properties at auction for a below‑market price — conduct constituting an actionable abuse of right under Article 19 of the Civil Code; (b) paragraph (d) of the REM, which appoints PNB as attorney‑in‑fact upon breach, made any acquisition by PNB inure to the benefit of the mortgagors; and (c) the Province of Negros Occidental was not an indispensable party. The RTC ordered reconveyance of Lots 778 and 788 to the plaintiffs upon payment of the acquisition price and expenses plus 12% interest.

Court of Appeals’ Rationale

The CA affirmed the RTC. Key points: (a) paragraphs (b) and (c) of the REM must be read in conjunction; when mortgagors failed to pay taxes, paragraph (c)’s last sentence obligated the mortgagee to advance taxes and insurance premiums, making PNB’s allowing tax delinquency and subsequent auction participation improper in context; (b) PNB waived the prescription defense by not raising it at trial and thereby could not raise it for the first time on appeal; and (c) paragraph (d) automatically appointed PNB as attorney‑in‑fact upon breach and the acquisition inured to the Tad‑ys, giving rise to a constructive trust over the acquired lots to prevent unjust enrichment.

Supreme Court’s Disposition and Overview of Analysis

The Supreme Court denied PNB’s petition and affirmed the CA’s decision. The Court analyzed separately the prescription/laches defense, the parties’ obligations under the REM regarding payment of real property taxes, the scope and effect of the agency clause in paragraph (d) of the REM, and the creation of a constructive trust.

Prescription and Laches — Court’s Analysis and Ruling

  • Procedural posture: PNB did not plead prescription in its answer nor raise it at the trial level; it first raised prescription on appeal. Under the Rules of Court, defenses not pleaded are deemed waived unless the bar by the statute of limitations is apparent from the pleadings or record. Jurisprudence permits raising prescription for the first time on appeal only when the bar is clearly, sufficiently and satisfactorily apparent on the record, or when no factual issues relevant to prescription arise.
  • The Court found the statutory basis for prescription unclear in this case. PNB cited Article 1144(1) (ten‑year action upon a written contract) in its appeal brief and later invoked Article 1144(2) in the petition on the theory that a constructive trust had arisen; this inconsistency demonstrated lack of clarity as to the applicable prescriptive period.
  • The complaint’s allegations and requested relief (breach of contract and reconveyance; allegations that the auction was null and void ab initio) left open multiple possible characterizations of the cause of action (e.g., challenge to validity of sale, breach of mortgage, reconveyance), each potentially carrying different prescription periods. As in Sanchez, such factual uncertainties preclude a summary dismissal on the basis of prescription.
  • Because PNB’s prescription defense was not clearly apparent from the pleadings or the record and involved factual matters (including the validity of the auction sale and whether the contract was void), it was inappropriate to consider the defense for the first time on appeal. The CA properly declined to decide prescription. The Court also noted the Tad‑ys’ long delay in pressing claims but held that laches involves factual inquiries better resolved at trial; PNB’s belated invocation of laches on appeal was similarly improper.

Obligation to Pay Real Property Taxes Under the REM — Court’s Interpretation

  • Contract interpretation principles: A contract is to be construed as a whole; doubtful stipulations take meaning from the contract’s entire context (Art. 1374 Civil Code). Paragraphs (b) and (c) of the REM were examined together. Paragraph (b) expressly places on the mortgagor the duty to pay taxes and assessments and to surrender official receipts. Paragraph (c) sets out events of default and foreclosure remedies, and the last sentence of paragraph (c) provides additional stipulations including that “the Mortgagee shall advance the taxes and insurance premiums due in case the Mortgagor shall fail to pay them.”
  • The Court concluded that the mortgagee’s obligation to advance taxes and insurance premiums arises only in the specific context of judicial foreclosure (as that last sentence supplements the prior sentences governing foreclosure). Accordingly, PNB’s obligation to pay the taxes did not arise as a general duty upon mere default short of judicial foreclosure. The Court therefore sustained PNB’s contention that its duty to advance taxes under that clause was tied to judicial foreclosure.

Agency under Paragraph (d) of the REM — Scope and Effect

  • Paragraph (d) of the REM provides for automatic appointment of the mortgagee as attorney‑in‑fact “effective upon the breach of any condition of this mortgage” with broad powers: to take possession, collect rents, eject tenants, lease or sell at private sale, execute documents, make repairs, pay expenses and “perform any other act which the Mortgagee may deem convenient for the proper administration of the mortgaged property.” The clause also guarantees repayment of advances and permits application of proceeds to indebtedness.
  • The Court acknowledged that Article 1878 of the Civil Code requires express authorization for powers of attorney to create, convey or transfer ownership of immovables; this requirement addresses acts of strict dominion. However, paragraph (d) is a general agency clause directed at acts of administration under Article 1877. Whether an act is administrative or one of strict dominion is ultimately a question of fact dependent on circumstances.
  • The Court held that paragraph (d)’s grant of power to “perform any other act…convenient for the proper administration” encompasses acts reasonably necessary to preserve and administer the mortgaged property for the purpose of protecting the mortgagee’s foreclosure rights, including participation in a tax delinquency auction to prevent loss to third parties. PNB admitted that it participated in the auction to protect its mortgage interest. The Court found this to be an act of administration (preserving the mortgagee’s ability to later alienate the property to satisfy the debt) rather than a manifestatio

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