Case Summary (G.R. No. 192345)
Factual Background
On October 27, 1997, the spouses Marcos and Susan M. Prieto initiated a complaint in the Regional Trial Court (RTC) in Bauang, La Union, to declare void several real estate mortgage contracts. The plaintiffs alleged that in January 1996, they authorized Antonio Prieto to borrow money from the bank, using their property as collateral. The loans were not repaid, leading to an impending foreclosure. The plaintiffs claimed that since the promissory notes and mortgage contracts were solely in the names of Antonio and Monette, these contracts were null and void from the outset.
RTC Ruling and Procedural History
Initially, the RTC issued a temporary restraining order against the foreclosure, but later denied the application for a preliminary injunction. Ultimately, on July 31, 2001, the court dismissed the complaint, ruling that even though Marcos's name was absent from the mortgage contracts, he could not avoid liability due to his agent's actions. The RTC noted that Marcos ratified the actions of Antonio by signing an acknowledgment letter, thus making him liable for the mortgages.
Marcos filed a motion for reconsideration, which the RTC denied. Subsequently, he filed a notice of appeal; however, it was deemed untimely as it was submitted four days late. Attempts to seek reconsideration of this ruling were also unsuccessful.
Court of Appeals Decision
Marcosa appealed to the Court of Appeals, alleging grave abuse of discretion by the RTC. The CA dismissed his petition, reinforcing that the appeal was not perfected on time, thus the RTC's decision was final. Marcos's claims regarding the failure of the CA to meet the requirement of unanimous voting were also addressed. The CA clarified that Justice GuariAa III had indeed concurred in the resolution.
Legal Principles and Analysis
The core legal principle discussed focuses on the ratification of actions by an agent. Under Article 1898 of the Civil Code, actions taken beyond the authority of an agent can still bind the principal if ratified. The Court emphasized that Marcos had effectively ratified Antonio's actions through his written acknowledgment.
Despite the petitioner's arguments alleging that the acknowledgment letter was a mere scrap of paper, the Court found that he could not dismiss the significance of his own written consent, especially as he was a lawyer aware of its implications. The Court further hig
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Case Overview
- The case revolves around the petition filed by Marcos against the Court of Appeals and several respondents, including banks and individuals, regarding the validity of real estate mortgage contracts and associated loans.
- The core issue involves the ratification of acts conducted by an agent (Antonio Prieto) and whether Marcos can be held liable for loans secured through mortgages on his property despite not directly signing the contracts.
Antecedents of the Case
- On October 27, 1997, Marcos and his wife, Susan Prieto, initiated a complaint in the Regional Trial Court (RTC) of Bauang, La Union.
- The complaint sought to declare null the real estate mortgage contracts executed by Antonio and Monette Prieto with Far East Bank and Trust Company (FEBTC) using Marcos's property as collateral.
- They contended that:
- Antonio was authorized via a Special Power of Attorney (SPA) to borrow money, but the loans were secured solely in the names of Antonio and Monette.
- They claimed the mortgages were null and void ab initio, as the debts were incurred exclusively for the benefit of Antonio and Monette.
RTC Proceedings
- The RTC issued a temporary restraining order and scheduled a preliminary hearing for a writ of preliminary injunction.
- On March 24, 1998, the RTC denied the application for the injunction, and this denial was upheld upon reconsideration.
- On July 31, 2001, the RTC dismissed the complaint, stating:
- Marcos could not claim a right of action against the agent (Antonio) since the contracts were executed in the name of the agent.
- The mortgage contracts were deemed valid as they were made on behalf of the principal (Marcos