Go v. Court of Appeals

G.R. No. 120040 (January 29, 1996)

Facts:

Petitioners Camilo and Delia Go secured a loan of P93,200.00 from Manuela Realty Development Corporation (Manuela) on June 15, 1978, constituting a real estate mortgage over their house and lot. The loan carried an interest rate of 14% per annum. Following the petitioners' alleged failure to repay the loan, Manuela initiated extrajudicial foreclosure proceedings. A public auction was held on September 9, 1989, where Manuela was the sole bidder, winning the auction with a bid of P251,151.74, which represented the petitioners' outstanding debt at that time. After the redemption period expired, Manuela consolidated ownership of the properties and obtained a new Transfer Certificate of Title.

In response, the petitioners filed a complaint for recovery of ownership against Manuela on August 21, 1989, later amending it on November 20, 1989. They claimed to have made a payment of $500 in 1982 and argued that their total payments exceeded the loan amount. They also contested the validity of the foreclosure and claimed that the interest rate was usurious, exceeding the legal ceiling of 12%. Manuela countered that the petitioners had defaulted on their payments, leading to the increase in their outstanding debt, and maintained that the foreclosure was valid and the interest rate lawful.

The petitioners moved for summary judgment, which Manuela opposed without submitting a counter-affidavit. The trial court denied the motion, finding genuine issues of fact that required a full hearing. The petitioners then sought a writ of mandamus from the Court of Appeals to compel the trial court to grant their motion for summary judgment, but this was also denied.

Legal Issues:

1. Whether the Court of Appeals erred in denying the petitioners' motion for summary judgment.
2. Whether mandamus can be used to compel the trial court to grant a motion for summary judgment when there are genuine issues of material fact.

Arguments:

• Petitioners' Argument: The petitioners argued that there was no genuine issue of material fact that warranted a trial, asserting that they had made payments exceeding their loan obligation. They contended that the trial court had a ministerial duty to grant their motion for summary judgment based on the absence of factual disputes.

• Respondent's Argument: Manuela contended that there were substantial and triable issues of fact, including the actual amount paid by the petitioners, the validity of the foreclosure, and the legality of the interest rate. They argued that the trial court's discretion in denying the motion for summary judgment was justified, as the presence of genuine issues necessitated a full trial.

Court's Decision and Legal Reasoning:

The Supreme Court affirmed the decision of the Court of Appeals, ruling that the petitioners' petition lacked merit. The Court clarified that mandamus is appropriate only to compel the performance of a ministerial duty, not a discretionary one. The decision to grant summary judgment is a matter of judicial discretion, and the petitioners failed to demonstrate a clear legal right to the relief sought.

The Court emphasized that the burden of proof lies with the party moving for summary judgment to show the absence of genuine issues of material fact. It noted that the presence of disputed facts, such as the amount paid by the petitioners and the circumstances surrounding their alleged defaults, warranted a trial rather than a summary judgment. The Court reiterated that summary judgment is only appropriate when there are no genuine issues of material fact, and the trial court's findings of triable issues were upheld.

Significant Legal Principles Established:

1. Mandamus: It cannot be used to compel a court to perform a discretionary act, such as granting a motion for summary judgment.
2. Summary Judgment: It is only appropriate when there are no genuine issues of material fact. The burden of proof lies with the movant to demonstrate the absence of such issues.
3. Discretion of the Court: Courts have the discretion to determine whether genuine issues of material fact exist, and litigants cannot dictate how cases should be resolved.