Thursday, July 6, 2023

Case Digest: Commercial Credit Corp. of Cagayan de Oro vs CA and Cagayan de Oro Coliseum, Inc. G.R No. 78315

Commercial Credit Corp. of Cagayan de Oro vs Court of Appeals and Cagayan de Oro Coliseum, Inc. GR No. 78315, January 2, 1989

Subject: Obligations and Contracts

FACTS

In 1978, private respondent, Cagayan De Oro Coliseum, Inc. (CDOCI) executed a promissory note in the amount of 329, 852.54 in favor of petitioner Commercial Credit Corporation of Cagayan De Oro (CCCCDO), payable in 36 monthly installments. The note is secured by a real estate mortgage duly executed by private respondent in favor of petitioner. Respondent then defaulted in the real payment and the petitioner proceeded with the extrajudicial foreclosure of the real estate mortgage in September 1979.

On March 11, 1980, a Compromise Agreement was entered into by the parties wherein the minority stockholders ratified and approved the loan and real estate mortgage, and as such, CDOCI hereby admits its total outstanding obligation to Commercial Credit Corporation of Cagayan de Oro and agreed to pay the obligation plus interest on diminishing balance computed yearly at sixteen (16) per cent per annum. Furthermore, it agreed to pay the aforegoing obligation in equal monthly installments of P11,000.00 the first installment shall be payable in February 1980 and every month thereafter until the whole account payable as aforementioned is fully paid, and that, failure on the part of Respondent Cagayan de Oro Coliseum, Inc. to pay any of the installments as they shall become due, the whole amount then outstanding and unpaid shall immediately become due and payable in its entirety and shall render the judgment herein to be immediately final, unappealable and executory; and the overdue and unpaid installments shall earn a three (3%) per cent monthly penalty charge until fully paid, plus five percent (5%) of the outstanding balance as additional attorney’s  fee. CCCCDO on its part agreed to withdraw its application for the extra-judicial foreclosure of the real estate mortgage subject of this complaint.

However, CDOCI failed to comply with the terms of the judgment for failure to pay several installments which matured on July 13, 1982, petitioner CCCCDO filed an ex-parte motion for the issuance of a writ of execution on March 4, 1983. On March 10, 1983 the Court of First Instance granted the motion, and a notice of auction sale was issued on March 11, 1983. After reviewing the respondent’s motion for reconsideration and the petitioner’s reply, the trail court accordingly denied the motion and issued the writ on December 4, 1986.

Private respondent then filed a special civil action in the Court of Appeals to annul said compromise-judgment, alleging that the trail court acted in serious violation of law and/or in grave abuse of discretion. In due course, a decision was rendered by said appellate court denying the petition.

A motion for reconsideration of the decision was filed by the petitioner but was denied.

ISSUE

Whether or not Article 1229 of the Civil Code is applicable in this case.

RULING

No, Article 1229 of the Civil Code is not applicable in this case.

Under the law (Art 1229), the judge shall equitably reduce the penalty when the principal obligation has been partly or irregularly complied with by the debtor. Even if there has been no performance, the penalty may also be reduced by the courts if it is iniquitous or unconscionable.

In this case, a compromise judgement is final and immediately executor. Once a judgment becomes final and executor, it cannot be modified and amended. When the parties entered into the compromise agreement and submitted the same for approval of the trail court, its terms and conditions must be the primordial consideration why the parties voluntarily entered into the same. The trail court approved it because it is lawful, and is not against public policy or morals. Even the respondent Court of Appeals unheld the validity of the said compromise agreement. Hence, the respondent court has no authority to reduce the penaly and attorney’s fees therein stipulated which is the law between the parties and is res judicata. Article 1229 applies only to an obligation or contractm subject of a litigation, the condition being that the same has been partly or irregularly complied with by the debtor. Said provision also applies even if there has been no performance, as long as the penalty is uniquitous or unconscionable. It cannot apply to a final and executory judgment.

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