Rural Bank of San Mateo Isabela, Inc. v. Ramales
REITERATIONFacts
The Antecedents: This case consolidates two petitions stemming from a dispute over foreclosed properties. Initially, spouses Myrvin and Josie Ramales donated properties to Alvarez-Ramales School Foundation, Inc. (ARSFI). Unbeknownst to ARSFI, the spouses Ramales mortgaged these properties, including one under TCT No. TSC-14700, to secure a loan from Rural Bank of San Mateo Isabela, Inc. (RBSMI). Upon default, RBSMI foreclosed the mortgage, becoming the highest bidder. Procedural History: In G.R. No. 256021, the spouses Ramales filed a petition to annul the extrajudicial foreclosure proceedings, alleging full loan payment. RBSMI moved to dismiss, citing lack of jurisdiction due to the spouses' failure to state the assessed value of the foreclosed properties. The Regional Trial Court (RTC) Branch 35 denied the motion, ordering the spouses to amend their petition. RBSMI's subsequent petition for certiorari with the Court of Appeals (CA) was dismissed, with the CA holding that a petition for review on certiorari was the proper recourse to this Court. In G.R. No. 268716, after acquiring ownership, RBSMI filed an ex-parte petition for a writ of possession. ARSFI sought to intervene and quash the writ, claiming ownership of the donated properties. RTC Branch 21 denied ARSFI's motions, and the CA affirmed this denial. The Petition: In G.R. No. 256021, RBSMI seeks review of the CA's dismissal of its certiorari petition, arguing that the RTC's denial of its motion to dismiss was an interlocutory order that could be assailed via certiorari under Rule 65, and that the RTC acted with grave abuse of discretion. In G.R. No. 268716, ARSFI seeks review of the CA's affirmation of the RTC's denial of its intervention and motions related to the writ of possession, asserting its adverse claim and ownership over the donated properties. Both petitions are filed under Rule 45 of the Rules of Court, seeking reversal of the respective CA decisions.
Issue(s)
Whether the CA erred in dismissing RBSMI's Petition for Certiorari for being the wrong mode to assail the RTC Branch 35's Order denying its motion to dismiss. Whether RTC Branch 35 acted with grave abuse of discretion amounting to lack or excess of jurisdiction in denying RBSMI's motion to dismiss and ordering the amendment of the petition. Whether the CA erred in holding that RTC Branch 21 did not act with grave abuse of discretion in issuing the writ of possession and in denying ARSFI's Urgent Motion to Intervene, Urgent Motion to Quash Writ of Possession, and Motion to Enjoin Sheriff.
Ruling
The Petitions for Review on Certiorari in G.R. Nos. 256021 and 268716 are DENIED for lack of merit. The February 10, 2020 Decision and January 6, 2021 Resolution of the Court of Appeals in CA-G.R. SP No. 153530, as assailed in G.R. No. 256021, as well as the February 22, 2023 Decision and the July 26, 2023 Resolution of the Court of Appeals in CA-G.R. SP No. 166173, questioned in G.R. No. 268716, are AFFIRMED.
Ratio Decidendi
On Issue 1: The Court ruled that RBSMI rightly filed a Petition for Certiorari under Rule 65 of the Rules of Court to question the June 2, 2017 Order of RTC Branch 35. An order denying a motion to dismiss is an interlocutory order, which, under Rule 41, Section 1(c) of the Rules of Court, is not appealable. The proper recourse for an aggrieved party against an interlocutory order is to file a special civil action for certiorari under Rule 65, provided there is proof that the order was issued with grave abuse of discretion amounting to lack or excess of jurisdiction. The CA's reliance on Republic v. Sunvar Realty Development Corporation was misplaced, as Sunvar involved a final order of dismissal, not an interlocutory one, making a Rule 45 petition appropriate in that specific context. Thus, the CA erred in dismissing RBSMI's Rule 65 petition on the ground of wrong mode of appeal. On Issue 2: The Court found that RBSMI failed to prove that RTC Branch 35 acted with grave abuse of discretion amounting to lack or excess of jurisdiction. RTC Branch 35 acted within the dictates of Rule 10, Section 1 of the Rules of Court by allowing the spouses Ramales to amend their petition to correct inadequate allegations, specifically regarding the foreclosure proceedings subject of the annulment. Furthermore, the spouses Ramales' failure to explicitly allege the assessed value of the foreclosed properties was not fatal to their petition for annulment of foreclosure proceedings. Applying the liberal stance adopted in Tumpag v. Tumpag and Crystal v. Son, the Court held that the assessed value could be determined from the Tax Declarations attached to the petition, which showed a total assessed value of PHP 92,840.00, well within the jurisdictional threshold of RTCs outside Metro Manila (PHP 20,000.00) at the time the petition was filed. On Issue 3: The Court held that RTC Branch 21 did not commit grave abuse of discretion in issuing the writ of possession and in denying ARSFI's Urgent Motion to Intervene, Urgent Motion to Quash Writ of Possession, and Motion to Enjoin Sheriff. The issuance of a writ of possession is generally ministerial, especially after the purchaser becomes the absolute owner of the foreclosed property. While this ministerial duty ceases if a third party holds the property adversely to the debtor-mortgagor, ARSFI failed to unmistakably establish its claim of ownership or adverse possession. ARSFI's witnesses (De Guzman and Rigos) were not presented in court to affirm their Judicial Affidavits, rendering them inadmissible under Section 10(b) of the Judicial Affidavit Rule. Moreover, the Deed of Donation, even if admitted, would only prove ARSFI as a successor or transferee, not an adverse party, and tax declarations alone are not conclusive evidence of ownership. Consequently, ARSFI also failed to establish the legal interest required for intervention under Rule 19, Section 1, as it did not prove its ownership or adverse possession over the donated properties.
Main Doctrine
This consolidated Decision clarifies and reiterates the procedural rules governing appeals from interlocutory orders, the determination of jurisdiction in real actions, and the requirements for the issuance of writs of possession and intervention in extrajudicial foreclosure proceedings. It emphasizes that an order denying a motion to dismiss is interlocutory and thus not appealable, but may be challenged via a special civil action for certiorari under Rule 65 if grave abuse of discretion is proven. The Court also affirms that the assessed value for jurisdictional purposes in real actions can be ascertained from documents appended to the complaint, even if not explicitly alleged. Furthermore, it reinforces the ministerial nature of a writ of possession for a purchaser in an extrajudicial foreclosure, subject to the strict condition that a third-party claimant must unequivocally establish adverse possession in their own right, and that the right to intervene is not absolute, requiring a direct legal interest and proper presentation of evidence.