Case Summary (G.R. No. 158238)
Antecedents
On February 14, 1995, Elizabeth B. Mendinueta executed a promissory note with Charlie Mancilla for a loan of ₱1,200,000.00, secured by a real estate mortgage on her residential property identified by Transfer Certificate of Title No. 87140, located in Parañaque City. The promissory note established a monthly interest of 5% and included stipulations regarding default and foreclosure. Elizabeth, who was recorded as "single," defaulted on the loan, leading Mancilla to file for judicial foreclosure before his death, at which point his heirs took over as plaintiffs.
Court Proceedings and Judgments
The Regional Trial Court (RTC) ruled in favor of Mancilla's heirs on September 25, 1997, ordering Elizabeth to pay the principal loan, interest, and attorney’s fees within 90 days, or face foreclosure of the mortgaged property. Elizabeth's appeal to the Court of Appeals was dismissed primarily due to her failure to file the required briefs. This dismissal led to a final and executory judgment recorded on November 15, 1999.
Subsequent Actions and Petition for Annulment
After Elizabeth's death, her children—petitioners in this case—sought to annul the RTC's decision, claiming their mother lacked the authority to mortgage as it constituted the family home under the Family Code, requiring spousal consent. Their petition alleged extrinsic fraud and lack of jurisdiction in the original proceedings, asserting that they were indispensable parties not included in Civil Case No. C-425 due to their minor status during the trial.
Dismissal by the Court of Appeals
The Court of Appeals dismissed the petition for annulment due to procedural deficiencies, particularly the failure to attach necessary documents and a lack of timely personal service. The petitioners contended that their claims were sufficient to warrant consideration, arguing they had provided adequate evidence of the familial ties and ownership of the property, which justified the annulment of the RTC’s judgment.
Legal Standard for Annulment of Judgments
The Court highlighted that under Section 4, Rule 47 of the Rules of Court, a verified petition must allege with particularity the facts and law relied upon for the annulment and support it with appropriate documents. This procedural requirement is stringent due to the extraordinary nature of annulment as a legal remedy. The petitioners failed to satisfy these requirements, leading to a justifiable dismissal of their case.
Jurisdictional Considerations
Jurisdiction over the original case was rightly established as there were no claims of extrinsic fraud or lack of jurisdiction affecting the trial court'
...continue readingCase Syllabus (G.R. No. 158238)
Background of the Case
- The case revolves around a loan agreement and subsequent foreclosure involving a real estate mortgage executed by Elizabeth B. Mendinueta, the mother of the petitioners, in favor of Charlie Mancilla.
- On February 14, 1995, Elizabeth secured a loan of P1,200,000.00 from Charlie Mancilla, promising to pay the amount with a monthly interest of 5%, secured by a mortgage on a residential property in ParaAque City.
- The mortgage was annotated on the title of the property, and Elizabeth was noted as "single" at the time of the mortgage execution.
- After Elizabeth failed to make payments, Mancilla filed for judicial foreclosure of the mortgage in Civil Case No. C-425.
Procedural History
- Following the death of Charlie Mancilla, his heirs were substituted in the case.
- A pre-trial was conducted where both parties acknowledged the validity of the loan and mortgage.
- The Regional Trial Court (RTC) eventually ruled in favor of Mancilla’s heirs, ordering Elizabeth to pay the loan, interest, and attorney’s fees, with the property set to be sold at public auction if she failed to comply.
- Elizabeth's appeal to the Court of Appeals was dismissed due to her failure to file a required brief, and her