Case Summary (G.R. No. 193453)
Case Background
The case revolves around the petitioners, Spouses Rubin and Portia Hojas, who entered into a loan agreement with the Philippine Amanah Bank for ₱450,000. The loan was secured by a mortgage on both personal and real properties owned by the petitioners. From 1981 to 1986, they paid a total of ₱486,162.13. However, the bank allegedly mismanaged their payments, leading to discrepancies that eventually culminated in an extrajudicial foreclosure initiated by PAB in 1987.
Timeline of Events
The timeline includes critical dates: on January 12, 1987, the bank issued a Notice of Extrajudicial Foreclosure, setting a sale date for April 21, 1987. A public auction was subsequently held, in which PAB acquired the mortgaged property. Despite this, a letter from then OIC-President of PAB indicated that the redemption period was extended until December 31, 1988, due to an incentive scheme, leading the petitioners to assert that the public auction held on November 4, 1988, was premature.
Initial Court Proceedings
In a subsequent legal battle, the Regional Trial Court (RTC) dismissed the petitioners' complaint on May 27, 1996, ruling that the bank acted in good faith throughout the foreclosure process and that the petitioners failed to redeem their properties within the allotted time. The court found that the sale to Kue was legitimate and above board.
Court of Appeals Decision
The decision of the RTC was appealed to the Court of Appeals (CA), which upheld the RTC’s ruling. The CA clarified that the December 31, 1988 date referenced in the letter did not extend the redemption period but related solely to the liberalized payment incentives offered to the petitioners. Consequently, the CA dismissed the appeal, confirming the RTC's findings.
Legal Principles and Arguments
The core issue before the Supreme Court was whether PAB violated the principle of estoppel by conducting the public sale before the alleged extended redemption period. The petitioners contended that their reliance on the bank's statements prevented the sale. Conversely, PAB argued that the principle of estoppel does not apply, as the letter from Carpizo was not an unqualified assertion that the redemption period was extended.
Supreme Court Analysis
The Supreme Court found that the bank’s representation regarding the incentive scheme did not equate to an extension of the redemption period. The court reiterated that the right to redeem a property involves not just the exp
...continue readingCase Syllabus (G.R. No. 193453)
Case Background
- The case is a petition for review on certiorari challenging the decision of the Court of Appeals (CA) dated July 28, 2010, which affirmed the Regional Trial Court (RTC) decision dismissing the petitioners' complaint.
- The underlying issue arose from a loan secured by the petitioners from Philippine Amanah Bank (PAB) amounting to P450,000.00, secured by a mortgage over personal and real properties.
- The petitioners, Spouses Rubin and Portia Hojas, claimed to have made various payments totaling P486,162.13 from May 14, 1981, to June 27, 1986, but alleged that PAB did not properly credit these payments.
Allegations of Payment Mismanagement
- The petitioners asserted that only 13 payments were acknowledged by PAB, totaling only P317,048.83, and that payments amounting to P165,623.24 were uncredited.
- As of October 17, 1984, PAB’s statement indicated the petitioners owed P550,683.63, despite their total payments being P486,162.13.
Extrajudicial Foreclosure Proceedings
- Due to the petitioners' alleged failure to repay the loan, PAB initiated extrajudicial foreclosure proceedings.
- A Notice of Extrajudicial Foreclosure was issued on January 12, 1987, declaring a foreclosure sale set for April 21, 1987, with the mortgage debt still listed at P450,000.00.
- The mortgaged properties were sold to Ramon Kue during a public auction.
Legislative Intervention and Redemption Issues
- After the foreclosure, Senator Aquilino Pimentel intervened, leading to a letter from PAB’s OIC-President, Farouk A. Carpizo, extending the