G.R. No. 256021 & G.R. No. 268716, April 02, 2025
RURAL BANK OF SAN MATEO ISABELA, INC. vs. MYRVIN A. RAMALES AND JOSIE A. RAMALES; ALVAREZ-RAMALES SCHOOL FOUNDATION, INC. vs. RURAL BANK OF SAN MATEO, (ISABELA) INC.

FACTS

In G.R. No. 256021 , spouses Myrvin and Josie Ramales filed a Petition for Annulment of Extra-Judicial Foreclosure Proceedings against Rural Bank of San Mateo Isabela, Inc. (RBSMI). Their petition failed to allege the assessed value of the foreclosed properties. RBSMI moved to dismiss the case for lack of jurisdiction, arguing the court could not determine if it met the jurisdictional amount. The Regional Trial Court (RTC) denied the motion to dismiss and instead ordered the spouses to amend their petition to include the assessed value.
In G.R. No. 268716, the consolidated case involves Alvarez-Ramales School Foundation, Inc. (ARSFI). The spouses Ramales, who were incorporators of ARSFI, had donated a property to the foundation. Unknown to ARSFI, the spouses later mortgaged the same property to RBSMI. Upon the spouses’ loan default, RBSMI foreclosed and acquired the property. ARSFI later filed an Urgent Motion to Intervene and a Motion to Quash the Writ of Possession issued in favor of RBSMI, claiming ownership as an innocent donee.

ISSUE

The core issues are: (1) Whether the RTC committed grave abuse of discretion in G.R. No. 256021 by ordering an amendment to the petition instead of dismissing it for lack of jurisdictional allegations; and (2) Whether ARSFI in G.R. No. 268716 has a legal right to intervene in the extrajudicial foreclosure proceedings and challenge the writ of possession.

RULING

The Supreme Court denied both petitions. For G.R. No. 256021 , the Court ruled that the RTC did not commit grave abuse of discretion. An order denying a motion to dismiss is interlocutory and generally not appealable. A special civil action for certiorari under Rule 65 is only proper if the denial was issued without or in excess of jurisdiction or with grave abuse of discretion. Here, the RTC acted within its authority under Rule 10, Section 1 of the Rules of Court, which allows amendment of pleadings to cure defective allegations, including the omission of the assessed value necessary to determine jurisdiction. The RTC’s order to amend was a prudent exercise of discretion to determine the actual merits of the case.
For G.R. No. 268716, the Court held that ARSFI has no legal right to intervene in the issuance of the writ of possession. A writ of possession is a ministerial act following a consolidation of title in favor of the purchaser in an extrajudicial foreclosure. The proceeding is summary in nature and not an appropriate venue to litigate claims of ownership by third parties. ARSFI’s claim of ownership, derived from a donation, is an independent claim that must be asserted in a separate judicial action, not through a motion to intervene in the execution of the writ. Its remedy is a separate action to nullify the mortgage or to recover the property.