CRISTETA BAUTISTA v. MANGALDAN RURAL BANK

FACTS:

The case is a petition for review on certiorari filed by petitioners against Mangaldan Rural Bank, Inc., Register of Deeds of Pangasinan, Efren Rodriguez, and the Court of Appeals. The petitioners sought to set aside the decision of the Court of Appeals and confirm the lower court's decision.

Cristeta Bautista mortgaged her conjugal share of 1/2 of the land to Mangaldan Rural Bank for P2,000.00. The mortgage was foreclosed, and ownership over the entire land was consolidated in the name of the defendant bank. The defendant bank then sold the whole property to Efren Rodriguez.

The petitioners filed a complaint to annul and/or cancel various documents related to the property. The lower court ruled in favor of the petitioners, annulling the mentioned documents to the extent of one-half pro-indiviso of the land. The defendants were ordered to place the petitioners in possession of one-half pro-indiviso of the land and to pay damages, attorney's fees, and litigation expenses.

The defendants appealed to the Court of Appeals, which set aside the awards for damages, attorney's fees, and litigation expenses. The petitioners argue that the respondent bank committed gross negligence in selling the entire lot instead of only one-half to Efren Rodriguez. The Supreme Court found that the respondent court gravely abused its discretion and misapprehended the facts in setting aside the lower court's awards for damages and attorney's fees in favor of the petitioners.

ISSUES:

RULING:

PRINCIPLES:

  • The Court may review findings of fact of the Court of Appeals in exceptional instances where there is grave abuse of discretion or misapprehension of facts.

  • Gross negligence can warrant the award of damages and attorney's fees.