GR 88709; (February, 1992) (Digest)
G.R. No. 88709 . February 11, 1992.
NICOS INDUSTRIAL CORPORATION, JUAN COQUINCO and CARLOS COQUINCO, petitioners, vs. THE COURT OF APPEALS, VICTORINO P. EVANGELISTA, in his capacity as Ex-Officio Sheriff of Bulacan, UNITED COCONUT PLANTERS BANK, MANUEL L. CO, GOLDEN STAR INDUSTRIAL CORPORATION and THE REGISTER OF DEEDS FOR THE PROVINCE OF BULACAN, respondents.
FACTS
Petitioners filed a complaint for annulment of a sheriff’s sale, recovery of possession, and damages against respondents. They alleged that the foreclosure of their real estate mortgage securing a loan from United Coconut Planters Bank (UCPB) was invalid. Their grounds included irregularities in the publication of the auction notices and an unauthorized postponement of the sale date. After petitioners presented their evidence, respondents Golden Star Industrial Corporation and the sheriff filed a demurrer to evidence.
The trial court granted the demurrer and dismissed the complaint in a brief order dated June 6, 1986. The order stated only that the sheriff’s sale complied with Act No. 3135 and that the action appeared to be a derivative suit outside the court’s jurisdiction. The Court of Appeals affirmed this order. Petitioners elevated the case to the Supreme Court, contending the trial court’s order violated the constitutional mandate that decisions must state clearly and distinctly the facts and the law on which they are based.
ISSUE
Whether the trial court’s order granting the demurrer to evidence, which merely concluded that the sheriff’s sale was valid and the action was a derivative suit, complied with the constitutional requirement for decisions to state clearly and distinctly the facts and the law.
RULING
No. The Supreme Court set aside the decision of the Court of Appeals and remanded the case to the trial court. The Court held that an order granting a demurrer to evidence is a final adjudication on the merits, not a mere interlocutory order. As such, it falls under the constitutional command in Article VIII, Section 14, requiring that decisions state clearly and distinctly the facts and the law.
The trial court’s cursory order failed this test. It did not provide a factual or legal analysis of the evidence presented, such as the testimonies and exhibits regarding the alleged irregularities in the foreclosure publication and sale postponement. It merely declared conclusions without explanation. While decisions need not be lengthy, they must sufficiently articulate the basis for the ruling to enable the parties to understand it and facilitate any appellate review. The order in question, lacking such articulation, was constitutionally infirm. The case was remanded for the trial court to issue a revised order complying with the constitutional requirement.