Title
Trans Industrial Utilities, Inc. vs. Metropolitan Bank and Trust Co.
Case
G.R. No. 227095
Decision Date
Jan 18, 2021
Petitioners defaulted on loans secured by land, disputed authority and overpayment; Supreme Court upheld validity of agreements and denied claims due to lack of evidence.

Case Summary (G.R. No. 126297)

Antecedents

Trans Industrial, based in Mandaue City, Cebu, obtained several loans from Metrobank, which were secured by an assignment of property, TCT No. 38486. Due to insufficient collateral, the petitioners executed multiple Continuing Surety Agreements to cover loans totaling approximately P16 million and $626,000. After defaulting on these loans, Trans Industrial sought restructuring, resulting in a Debt Settlement Agreement in September 2000, which included a Deed of Dacion En Pago over another property (TCT No. 45993) in exchange for partial settlement.

Ruling of the RTC

On November 27, 2009, the Regional Trial Court (RTC) ruled in favor of the plaintiff, Meridian, and ordered the petitioners to pay P37,985,078.49, inclusive of interest and penalties, citing non-payment despite prior agreements and demands.

Ruling of the CA

The Court of Appeals (CA) upheld the RTC decision on October 30, 2015, finding the petitioners had failed to sufficiently contest the executed documents—particularly the Secretary's Certificate and the Debt Settlement Agreement. The court emphasized that the petitioners’ failure to deny these documents under oath constituted an admission of their genuineness and due execution. Furthermore, the CA found no evidence of fraud regarding the Debt Settlement Agreement.

Petitioners' Claims

In their petition to the Supreme Court, the petitioners raised several grounds, including the assertion that the resolutions authorizing loans beyond specified limits were void due to a lack of quorum, that agreements converting dollar loans to pesos were invalid, and claims of overpayment arising from the properties' perceived value. The petitioners maintained that they did not authorized borrowing in foreign currency, and argued that their loan obligations were fulfilled through the Dacion en Pago.

Respondent's Position

Respondent Meridian contended that the petitioners had already admitted the validity of the underlying documents by failing to specifically deny them under oath, and that the agreements concerning the loans and their amounts were valid and binding. Meridian rebutted the claims of overpayment by pointing out the explicit terms of the Debt Settlement Agreement and related documents.

Supreme Court's Ruling

The Supreme Court found the petition to be without merit and reiterated that the issues raised predominantly involved questions of fact rather than of law. The court emphasized that the determination of f

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