Case Summary (G.R. No. 64220)
Applicable Law
The relevant law in this case includes provisions of the 1987 Constitution of the Philippines, particularly regarding property rights and due process, alongside Presidential Decree No. 385 and the principles governing injunctions in property disputes.
Factual Background
On May 17, 1972, Searth borrowed ₱370,000 from DBP, securing the loan with multiple properties, including agricultural land and residential lots owned by the individual petitioners. A series of natural disasters severely affected Searth's operations, leading to unserviceable debt.
Following Presidential Decree No. 27, which proclaimed land reform across the nation, the petitioners lost possession of their agricultural land. By 1974, DBP foreclosed on the properties due to non-payment, and later attempted to sell previously foreclosed residential properties in 1980. The petitioners filed Civil Case No. 39128 in 1980, alleging that the foreclosure sale lacked proper publication and was thus void, asserting that their loan was oversecured and that they were willing to settle the remaining balance.
Procedural History
After initial proceedings, the court upheld the validity of the foreclosure sale, citing Section 2 of P.D. No. 385, which restricts the issuance of restraining orders against government financial institutions. The respondents argue that the regulatory framework denies the issuance of injunctions against DBP’s actions related to foreclosures, and that petitioners had remedies available to protect their interests, such as filing a lis pendens.
Court of Appeals' Ruling
The Court of Appeals upheld the trial court's decision, affirming that the provisions of P.D. No. 385 were applicable, even if the sale of the residential properties did not technically fall under foreclosure proceedings. The court held that the DBP had a right to dispose of its assets and that the petitioners had failed to demonstrate an existing right or irreparable damage warranting an injunction.
Supreme Court's Findings
The Supreme Court addressed key issues surrounding the issuance of an injunction, confirming that for it to be granted, a party must establish an existing right and show that the conduct against which the injunction is sought is infringing upon that right. The Court found that since the properties had been validly foreclosed upon and titled in DBP's name, the petitioners did not hold a valid claim over the prope
...continue readingCase Syllabus (G.R. No. 64220)
Case Overview
- Jurisdiction: Supreme Court of the Philippines
- G.R. No.: 64220
- Date of Decision: March 31, 1992
- Petitioners: Searth Commodities Corporation, Araceli Camacho, Prospero Castro, Manuel Tarroja
- Respondents: Court of Appeals, Development Bank of the Philippines (DBP)
Factual Background
- On May 17, 1972, Searth Commodities borrowed ₱370,000 from DBP to finance a tomato plantation in Tubao, La Union.
- Collateral for the loan included:
- 60 hectares of agricultural land in Tubao
- Farm machinery
- Residential lots and houses in Manila and Quezon City owned by the individual petitioners.
- In June 1972, floods and typhoons devastated the plantation.
- On October 21, 1972, Presidential Decree No. 27 proclaimed the country a land reform area, leading to farmers taking possession of the agricultural land.
- In 1974, DBP foreclosed on the properties due to Searth's failure to repay the loan.
Proceedings Before the Trial Court
- After the foreclosure, DBP consolidated title to the properties.
- On October 27, 1980, DBP announced plans to sell the residential properties.
- On October 30, 1980, petitioners filed Civil Case No. 39128, seeking annulment of the foreclosure and a writ of preliminary injunction against the sale of the properties.
Trial Court's Decisions
- Judge Rizalina Bonifacio-Vera initially issued a restraining order against the bid