Case Digest
Case Digest
Galabo
Case: G.R. No. 174191 Decision Date: Jan 30, 2013
Facts:
The case involves Nenita Quality Foods Corporation (NQFC) as the
petitioner and Crisostomo Galabo, Adelaida Galabo, and Zenaida Galabo-
Almachar as the respondents. The dispute centers on a parcel of land known
as Lot No. 102, PSD-40060, located in Marapangi, Toril, Davao City, covering
an area of 6,074 square meters. The respondents are the heirs of Donato
Galabo, who acquired Lot No. 722, a portion of the Arakaki Plantation, in
1948. They believed that Lot No. 722 included Lot No. 102 based on an
original survey conducted between 1916 and 1920. However, a resurvey by
the Board of Liquidators (BOL) in the 1950s excluded Lot No. 102 from Lot
No. 722. Despite this, the respondents continued to occupy and cultivate Lot
No. 102.
In the late 1950s, NQFC expressed interest in purchasing Lot No. 102,
but Donato declined and placed "Not For Sale" and "No Trespassing" signs on
the property. In the 1970s, Crisostomo Galabo fenced the lot and built a
house. On August 19, 1994, the respondents received a demand letter from
Santos Nantin, who claimed ownership of Lot No. 102 based on a Deed of
Transfer dated July 10, 1972, which the respondents allegedly executed in
his favor. The respondents denied this claim and maintained their long-
standing occupation of the lot, supported by letters and a certification from
the BOL acknowledging Donato as the awardee of Lot No. 102.
On January 3, 2001, NQFC's workers, accompanied by armed
policemen, forcibly entered Lot No. 102 to fence it. Following this, NQFC sent
a letter demanding that Crisostomo remove his house from the property.
NQFC claimed that Santos had occupied Lot No. 102 since 1972 and had
obtained a title for it. The respondents filed a complaint for forcible entry and
damages against NQFC in the Municipal Trial Court in Cities (MTCC), which
dismissed the complaint, stating that the issues required technical
determination by the BOL. The Regional Trial Court (RTC) upheld the MTCC's
decision, leading the respondents to appeal to the Court of Appeals (CA). The
CA reversed the lower court's decision, ruling in favor of the respondents,
prompting NQFC to file a petition for review on certiorari.
Issue:
1. Did the Court of Appeals err in ruling that the respondents had prior
physical possession of Lot No. 102?
2. Was the evidence presented by NQFC sufficient to establish its claim of
prior possession over Lot No. 102?
Ruling:
The Supreme Court denied the petition for review, affirming the
decision of the Court of Appeals. The Court held that the respondents had
prior physical possession of Lot No. 102 and that NQFC failed to prove its
claim of prior possession.
Title: Ermitano vs. Paglas
Case: G.R. No. 174436 Decision Date: Jan 23, 2013
Facts:
The case involves Juanita Ermitaao (petitioner), represented by her
attorney-in-fact, Isabelo Ermitaao, against Lailanie M. Paglas (respondent).
The events leading to the case began on November 5, 1999, when the
petitioner and respondent executed a Contract of Lease for a residential lot
and house located at No. 20 Columbia St., Phase 1, Doña Vicenta Village,
Davao City. The lease was for one year, starting on November 4, 1999, with
a monthly rental of P13,500.00. As part of the agreement, the respondent
paid a security deposit of P27,000.00 to cover any unpaid rentals or
damages.
Subsequently, the respondent learned that the petitioner had
mortgaged the property to Charlie Yap, which was foreclosed, and Yap
became the purchaser at an extrajudicial foreclosure sale registered on
February 22, 2000. On June 1, 2000, the respondent purchased the property
from Yap for P950,000.00, with a Deed of Sale executed that acknowledged
the petitioner's right of redemption.
Prior to this purchase, the petitioner filed a suit to declare the
mortgage null and void. On May 25, 2000, the petitioner demanded that the
respondent pay overdue rentals and vacate the premises, followed by a
second demand on March 25, 2001. When the respondent failed to comply,
the petitioner filed an unlawful detainer case against her on August 13,
2001, which was dismissed by the Municipal Trial Court in Cities (MTCC) on
November 26, 2001. The MTCC awarded the respondent P25,000.00 in
attorney's fees and P2,000.00 in appearance fees.
The petitioner appealed to the Regional Trial Court (RTC), which
affirmed the MTCC's decision but modified it by deleting the attorney's fees
and ordering the respondent to pay P135,000.00 for ten months of unpaid
rentals. The respondent then appealed to the Court of Appeals (CA), which
modified the RTC's decision, deleting the rental payment obligation and
reinstating a lower amount for attorney's fees. The petitioner subsequently
filed a motion for reconsideration, which was denied, leading to the current
petition for review on certiorari.
Issue:
1. Did the Court of Appeals err in dismissing the unlawful detainer case
by ruling that a sheriff's final certificate of sale had already been
issued?
2. Did the Court of Appeals err in ruling that the private respondent was a
buyer in good faith despite being informed by the petitioner that the
mortgage contract was allegedly a product of forgery?
3. Did the Court of Appeals err in awarding attorney's fees that had been
deleted by the RTC despite the absence of justification?
Ruling:
1. The Court affirmed the CA's decision, ruling that the unlawful detainer
case was properly dismissed based on the presumption of validity of
the mortgage and foreclosure sale.
2. The Court upheld the CA's finding that the respondent was a buyer in
good faith, as she relied on the validity of the documents.
3. The Court modified the CA's ruling regarding attorney's fees, ordering
the deletion of the award to the respondent.
Title: Heirs of Ignacio vs. Home Bankers Savings and Trust Co.
Case: G.R. No. 177783 Decision Date: Jan 23, 2013
Facts:
The case involves the petitioners, the Heirs of Fausto C. Ignacio,
namely Marfel D. Ignacio-Manalo, Milfa D. Ignacio-Manalo, and Faustino D.
Ignacio, against the respondents, Home Bankers Savings and Trust
Company, and spouses Phillip and Thelma Rodriguez, along with Catherine,
Reynold, and Jeanette Zuniga. The events leading to the case began in
August 1981 when Fausto C. Ignacio mortgaged two parcels of land located
in Cabuyao, Laguna, to Home Savings Bank and Trust Company, the
predecessor of the respondent bank, as collateral for a loan of P500,000.00.
Following his default on the loan, the bank foreclosed the mortgage, and on
January 26, 1983, it acquired the properties at a foreclosure sale for
P764,984.67. The Certificate of Sale was registered on February 8, 1983, and
after the redemption period lapsed, the titles were consolidated in favor of
the bank.
Despite the consolidation, Ignacio expressed a desire to repurchase
the properties, but no formal agreement was executed. The petitioners
claimed that a verbal agreement was reached, while the bank proceeded to
sell portions of the properties to third parties, including the intervenors,
without notifying Ignacio. In 1989, Ignacio filed a complaint for specific
performance and damages against the bank, seeking reconveyance of the
properties after paying a balance of P600,000.00. The Regional Trial Court
(RTC) initially ruled in favor of Ignacio, declaring the sales to the intervenors
null and void and ordering the bank to reconvey the properties. However, the
Court of Appeals (CA) later reversed this decision, leading to the present
petition for review on certiorari.
Issue:
1. Was there a perfected contract to repurchase the foreclosed properties
between the petitioner and the respondent bank?
2. Did the Court of Appeals commit grave abuse of discretion in reversing
the trial court's findings regarding the nature of the transactions and
the status of the intervenors as innocent purchasers for value?
Ruling:
The Supreme Court affirmed the decision of the Court of Appeals,
ruling that no perfected contract for repurchase existed between the
petitioner and the respondent bank. The Court also found no grave abuse of
discretion in the CA's reversal of the trial court's findings.