G.R. No. L-25510 October 30, 1970
CANDELARIA PECSON JOSE and DR. JOSE S. JOSE, plaintiffs-appellees, vs. PRISCILA SANTOS, INES SANTOS and MONS. PEDRO P. SANTOS, defendant-appellants.

FACTS

On December 10, 1960, defendant Priscila Santos, on her own behalf and as attorney-in-fact for the other defendants, borrowed P714,786.65 from plaintiff Candelaria Pecson Jose, payable in installments from March 15, 1961, to December 31, 1970. To secure payment, a first mortgage on two parcels of land in Rizal was executed on December 19, 1960, and registered. The mortgage stipulated that failure to pay any installment would render the entire obligation due. Defendants paid only up to the June 30, 1961, installment, leaving a balance of P561,093.40 unpaid despite demands. Plaintiffs filed a foreclosure complaint. Defendants, in their answer, denied the allegations and raised five special defenses with counterclaims, including a claim that plaintiffs failed to credit them P200,250.00 as reimbursement for registration expenses of a jointly owned hacienda, and other claims related to titles, firearm purchases, and alleged fraudulent use of a power of attorney. After trial, the lower court ordered defendants to pay P553,096.00 within 90 days, with foreclosure ordered in case of default, awarded plaintiffs P50,000.00 in attorney’s fees, and dismissed the special defenses and counterclaims for lack of merit, though it did discuss the P200,250.00 claim in detail. Defendants appealed, raising fourteen errors, including a constitutional claim that the lower court violated Article VIII, Section 12 of the Constitution by not stating clearly and distinctly the facts and law for dismissing five special defenses.

ISSUE

1. Whether the lower court violated the constitutional requirement that a decision of a court of record must express “clearly and distinctly the facts and the law on which it is based” by summarily dismissing five special defenses as “lacking in merit.”
2. Whether the lower court correctly ordered the foreclosure of the mortgage and dismissed the defendants’ special defenses and counterclaims.

RULING

1. No, the lower court did not violate the constitutional requirement. The Constitution mandates clarity and distinctness in judicial decisions to ensure scrutiny, inform litigants, and aid appellate review. However, there is no rigid formula; judicial discretion in language is broad. The lower court’s decision, while terse in dismissing five special defenses, was clear and distinct overall. It explained why the first special defense (the P200,250.00 claim) failed and found the others meritless on the established facts. The decision adequately showed why plaintiffs prevailed under the law applied to the proven facts, thus complying with constitutional standards.
2. Yes, the lower court correctly ordered foreclosure and dismissed the defenses. The obligation became due and demandable under the promissory note and mortgage due to defendants’ default in installments. The lower court properly reduced the claimed amount to P553,096.00 after crediting admitted payments and deducting additional sums. Its factual findings, including the rejection of the P200,250.00 claim and other alleged payments, were based on evidence and witness credibility, primarily within the trial court’s domain. The other special defenses were irrelevant to the core issue of default and were correctly dismissed. The appellate court found no arbitrariness in the lower court’s conclusions and affirmed its decision.
The appealed decision is affirmed, with costs against appellants.