Case Summary (G.R. No. 193346)
Antecedent Facts
The spouses executed mortgages on two lots located in Valencia City, Bukidnon, and three lots in Cagayan de Oro City to secure their loans. By August 31, 2001, their total obligation to PNB amounted to ₱16,534,803.29, which went unpaid upon maturity. Consequently, PNB initiated extrajudicial foreclosure proceedings on November 21, 2002, in the Regional Trial Court (RTC) of Cagayan de Oro City and the next day in Malaybalay City for their respective properties. Two public auctions were held on January 15, 2003, where PNB submitted its bids equivalent to the amount of the indebtedness, totaling ₱33,069,606.58, ultimately acquiring both properties.
Legal Proceedings Initiated by Respondents
On October 23, 2003, Spouses Roque sought to have the second foreclosure sale annulled, claiming their principal obligation was extinguished when PNB bought the first set of properties. During the pre-trial, they acknowledged their indebtedness at ₱22,230,269.57, while PNB claimed it mistakenly bid on the Valencia properties, believing the bid should have been ₱4,785,000. PNB attempted to correct this post-sale via a letter, but it was deemed untimely.
Trial Court Ruling
On December 19, 2005, the RTC upheld both foreclosure sales as valid, ordering PNB to return a balance of ₱10,839,337.01, plus interest, to the respondents. PNB's subsequent motion for reconsideration was denied. The notice of appeal, filed late and purportedly without the requisite payment of appeal fees, faced motions to disallow from the respondents.
Court of Appeals’ Response
The Court of Appeals (CA) affirmed the RTC's decision, citing PNB’s failure to perfect its appeal due to late payment of docket fees. PNB then sought recourse via a Petition for Certiorari, claiming grave abuse of discretion by the RTC, but the CA denied this as well.
Issues Presented
The Supreme Court confronted three primary issues:
- The appropriateness of liberally construing the rules regarding the perfection of appeal considering the circumstances surrounding PNB's late fee payment.
- The validity of the foreclosure sale itself.
- The potential inconsistency of the RTC's ruling with the causes of action proposed by the respondents.
Judicial Ruling on Appeal Perfection
The Supreme Court denied PNB's petition, agreeing with the CA's finding that while the notice of appeal was timely filed, it was not perfected due to the failure to pay required fees within the prescribed timeframe. The court reiterated that such payment is a critical requirement for a court to acquire jurisdiction over an appeal.
Justification for Upholding Foreclosure Validity
Regarding the validity of the foreclosure sa
...continue readingCase Syllabus (G.R. No. 193346)
Background and Nature of the Case
- The case is a Petition for Review on Certiorari under Rule 45 of the 1997 Rules of Civil Procedure.
- Filed by petitioner Philippine National Bank (PNB) to reverse the Court of Appeals' (CA) decisions dated November 26, 2009, and July 29, 2010.
- Arises from extrajudicial foreclosures of properties mortgaged by Spouses Rogelio and Evelyn Roque to PNB.
Facts of the Case
- The Spouses Roque executed real estate mortgages over two lots in Valencia City, Bukidnon, and three lots in Cagayan de Oro City securing loans from PNB.
- As of August 31, 2001, the mortgage obligation reached Php 16,534,803.29.
- Respondents failed to pay their loans upon maturity.
- PNB filed extrajudicial foreclosure petitions on November 21 and 22, 2002, in RTC courts of Cagayan de Oro City and Malaybalay City for properties located therein.
- Separate auctions held on January 15, 2003, for Cagayan de Oro City properties (first sale) and Valencia City properties (second sale).
- PNB submitted bids of Php 16,534,803.29 for each property group, totalizing Php 33,069,606.58, and was the sole bidder.
- Certificates of Sale were issued to PNB for both sales.
Subsequent Legal Actions and Claims
- On October 23, 2003, respondents filed a Complaint for Annulment of Sale, Cancellation of Certificate of Sale, Injunction, and Damages before the RTC of Malaybalay City.
- The complaint sought annulment of the second foreclosure sale (Valencia City properties), claiming the principal obligation was extinguished after the first sale.
- During pre-trial, both parties admitted indebtedness and bidding amounts: respondents admitted Php 22,230,269.57 as debt; PNB admitted a total bid of Php 33,069,606.58.
Allegation of Mistake and Correspondence Regarding Bid
- PNB claimed a mistake in bidding for Valencia City properties, stating it should have bid Php 4,785,000.00 instead of Php 16,534,803.29.
- PNB sent a letter dated January 15, 2003, to correct