Hiponia-Mayuga v. Metropolitan Bank
REITERATIONFacts
The Antecedents: Catherine Hiponia-Mayuga (Catherine) and her late husband Fernando J. Mayuga (Fernando) owned a parcel of land. Fernando, engaged in business, obtained a loan from Metropolitan Bank and Trust Co. (Metrobank) amounting to ₱2,200,000.00 on March 28, 1996, secured by a real estate mortgage (REM) over their property. Catherine consented to this mortgage. The loan was increased to ₱3,200,000.00 on July 3, 1996, with an amendment to the REM. Catherine claimed the loan proceeds went to Belle Avelino (Belle), though Belle admitted giving Fernando ₱100,000.00 on two occasions. Fernando passed away on November 17, 1996. Catherine inquired about releasing the property due to Mortgage Redemption Insurance (MRI), but Metrobank stated Belle was the principal borrower. On August 5, 1998, Catherine filed a complaint for cancellation of the REM and release of title against Belle, Metrobank, and Thelma Mauricio (Metrobank branch head), alleging collusion between Belle and Thelma. The mortgaged property was foreclosed by Metrobank due to Belle's non-payment, with Metrobank as the sole bidder. Procedural History: The Regional Trial Court (RTC), Branch 274, Paranaque City, ruled in its September 25, 2009 Decision that the mortgage contract was valid and properly foreclosed. It dismissed the complaint against Metrobank and Thelma for lack of proven collusion but ordered Belle to pay Catherine damages amounting to ₱2,988,800.00 as actual damages, ₱200,000.00 as moral damages, and ₱100,000.00 as attorney's fees. Catherine's motion for reconsideration was denied. Catherine appealed to the Court of Appeals (CA) regarding the dismissal of her complaint against Metrobank and Thelma. The CA, in its October 10, 2013 Decision, modified the RTC decision by deleting the award of damages against Belle, holding Fernando as an accommodation mortgagor. The CA denied Catherine's motion for reconsideration in a Resolution dated February 24, 2014. The Petition: Catherine filed a petition for review on certiorari seeking to reverse the CA's decision, arguing that the CA erred in deleting the damages against Belle (who did not appeal), in upholding the ruling of no connivance between Belle and Thelma, and in upholding the ruling that Metrobank was not negligent for failing to secure MRI for Fernando.
Issue(s)
Whether the Court of Appeals erred in modifying the RTC decision by deleting the award of damages against Belle Avelino, who did not appeal the RTC decision. Whether the Court of Appeals erred in upholding the RTC's ruling that there was no connivance between Belle Avelino and Thelma Mauricio in the execution of the real estate mortgage. Whether the Court of Appeals erred in upholding the RTC's ruling that Metrobank committed no negligence despite failing to secure a Mortgage Redemption Insurance (MRI) for Fernando J. Mayuga.
Ruling
The petition is PARTIALLY GRANTED. The October 10, 2013 Decision and the February 24, 2014 Resolution of the Court of Appeals are AFFIRMED WITH MODIFICATION. The award of damages against Belle Avelino in favor of petitioner Catherine Hiponia-Mayuga, as stated in the September 25, 2009 Decision of the Regional Trial Court, is REINSTATED.
Ratio Decidendi
On the issue of Belle Avelino's non-appeal and the award of damages: The Court held that Belle's failure to perfect an appeal within the prescribed period rendered the RTC decision final and executory as to her. Consequently, the appellate court lost jurisdiction to review or alter that judgment. An appellee who has not appealed cannot obtain affirmative relief from the appellate court beyond what was granted by the lower court. Therefore, the CA erred in deleting the award of damages against Belle, as the RTC decision in favor of Catherine on this point must be upheld. The CA's reliance on Section 8, Rule 51 of the Rules of Court was misplaced because the exceptions therein are for the benefit of the appellant, not the appellee. On the issue of connivance between Belle Avelino and Thelma Mauricio: The Court affirmed the findings of the RTC and the CA that the execution of the mortgage contract was not attended by collusion. The Supreme Court, as a rule, is not a trier of facts and defers to the factual findings of the lower courts, especially when they are in full agreement. The Court found no reason to disturb the consistent findings of the RTC and CA that no collusion was proven between Belle and Thelma. On the issue of Metrobank's alleged negligence in failing to secure MRI: The Court ruled that Catherine could not claim damages from Metrobank for its failure to secure MRI for Fernando. Neither the mortgage contract nor the law requires banks to secure MRI for accommodation mortgagors. Catherine failed to prove that securing MRI for accommodation mortgagors is an established banking practice, and the records did not show proof of Metrobank's negligence in this regard. Thus, Metrobank cannot be held liable for this alleged omission.
Main Doctrine
An appellee who has not himself appealed cannot obtain from the appellate court any affirmative relief other than those granted in the decision of the court below. The exceptions under Section 8, Rule 51 of the Rules of Court, allowing the appellate court to decide issues not raised in the assignment of errors, are for the benefit of the appellant, not the appellee.