G.R. No. 243968.

March 22, 2022 (Case Brief / Digest)

Title: **Paglaum Management & Development Corp. and Health Marketing Technologies,
Inc. vs. Union Bank of the Philippines, et al.**

**Facts:**
This case involves Paglaum Management & Development Corp. (Paglaum) and Health
Marketing Technologies, Inc. (HealthTech) as petitioners, and Union Bank of the Philippines
(Union Bank), a notary public referred to as John Doe, and the Register of Deeds of Cebu
City and Cebu Province as respondents. Initially, HealthTech had entered into a
restructuring agreement with Union Bank on 11 December 1998 after obtaining loans that
were secured by real estate mortgages dated 11 February 1994 and 22 April 1998, to which
Paglaum was also a party.

The central issue arose when Union Bank filed a motion for the reconsideration of the
Supreme Court’s decision dated 18 June 2012, arguing that the restructuring agreement
was null and void due to non-compliance with a condition precedent by the borrower. Union
Bank contended that this nullity revived the original real estate mortgages, which stipulated
a different venue for legal disputes. Additionally, Union Bank argued that Paglaum was not
a party to the restructuring agreement and therefore, any legal actions should be
exclusively lodged in Cebu City as per the original mortgage contracts. Lastly, Union Bank
claimed that the complaint, being an action for recovery of possession (accion
reivindicatoria), falls outside the jurisdiction of the Regional Trial Court (RTC) due to the
lack of stated assessed value of the property in question.

The procedural posture of this case involved the escalation of these issues through the
Philippine legal system, eventually reaching the Supreme Court after Union Bank’s motion
for reconsideration of the RTC’s decision to assume jurisdiction over the case.

**Issues:**
1. Whether issues raised for the first time in a motion for reconsideration before the
Supreme Court should be considered.
2. Whether the Restructuring Agreement was null and void, hence reviving the original real
estate mortgages with a different venue stipulation for legal disputes.
3. The applicability of the venue stipulation in the original mortgage contracts to Paglaum,
not being a party to the Restructuring Agreement.
4. Whether the lack of the stated assessed value of the property in the complaint removes
the jurisdiction of the RTC over the case.

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 G.R. No. 243968. March 22, 2022 (Case Brief / Digest)

**Court’s Decision:**
The Supreme Court denied the motion for reconsideration with finality, reiterating its
position that issues raised for the first time at the motion for reconsideration stage are
deemed waived as they should have been presented earlier. Further, it held that the matters
requiring factual determination raised by Union Bank fell within the jurisdiction of the RTC
and not the Supreme Court. The Court dismissed Union Bank’s last contention, having
already resolved it in their decision dated 18 June 2012.

**Doctrine:**
Issues not raised at the earliest opportunity in a judicial proceeding are deemed waived. The
Supreme Court of the Philippines emphasizes that the proper venue for factual disputes and
evidence presentation is the lower courts, specifically, the RTC. Additionally, this case
reiterates the principle that a mere rehash of already resolved issues does not warrant
reconsideration by the Supreme Court.

**Class Notes:**
– **Doctrine of Waiver of Issues**: Legal points not presented at the earliest opportunity are
considered waived.
– **Venue Stipulation in Contracts**: Contractual stipulations about venue of legal disputes
are enforceable, subject to specific exceptions.
– **Jurisdiction of RTC in Accion Reivindicatoria**: The jurisdiction of the RTC in actions for
recovery of possession is determined by the assessed value of the property, which must be
explicitly stated.
– **Supreme Court’s Role in Factual Determinations**: The Supreme Court does not
function as a trier of facts; this role is designated to the lower courts.

**Historical Background:**
This case illustrates the complexities involved in financial restructuring agreements and the
enforcement of contractual stipulations, particularly venue clauses, in the Philippines. It
underscores the importance of compliance with procedural rules and the delineation of
jurisdictions among different levels of courts under the Philippine legal system. The decision
reaffirms key procedural doctrines and illustrates the challenges entities face in navigating
the Philippine judicial process when financial agreements fall into dispute.

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