GR 207004; (June, 2018) (Digest)
G.R. No. 207004, June 06, 2018
ASTRID A. VAN DE BRUG, MARTIN G. AGUILAR AND GLENN G. AGUILAR, PETITIONERS, VS. PHILIPPINE NATIONAL BANK, RESPONDENT.
FACTS
The late spouses Romulus and Evelyn Aguilar obtained sugar crop loans from Philippine National Bank (PNB), secured by a real estate mortgage over four parcels of land. Due to non-payment, PNB foreclosed the mortgage in 1985 and consolidated ownership of the properties. Following the enactment of the Sugar Restitution Law (R.A. No. 7202), the Aguilars sought recomputation of their foreclosed loan. PNB, via a 1997 letter, informed the surviving spouse, Evelyn Aguilar, that the account was covered by R.A. 7202 but required her to comply with specific conditions within 60 days: arrange for restructuring, signify conformity to the COA-audited recomputation, and submit crop production data.
The Aguilars claimed compliance and were furnished statements of account, the latest showing a total obligation of over P2.2 million as of November 1999. They also alleged that PNB advised them that the agricultural lots had been voluntarily conveyed to the Department of Agrarian Reform (DAR) and that proceeds from the Land Bank of the Philippines (LBP) would be applied to their loan, with any excess returned to them along with the residential lot. However, PNB later denied any right to excess proceeds, stating it had acquired full ownership after foreclosure. The Aguilars filed a case for the implementation of R.A. 7202.
ISSUE
Whether the Aguilars are entitled to the benefits under R.A. No. 7202, specifically to a recomputation of their loan and any excess proceeds from the sale of the foreclosed properties to DAR.
RULING
No. The Supreme Court denied the petition, affirming the Court of Appeals’ reversal of the RTC. The legal logic hinges on the Aguilars’ failure to validly avail themselves of the law’s benefits. R.A. 7202 provides a conditional right; borrowers must comply with the mandatory procedures outlined in its Implementing Rules and Regulations (IRR). PNB’s 1997 letter clearly stipulated the requirements for restructuring under the law. The Court found that the Aguilars failed to formally signify their conformity to the COA-audited recomputation, a crucial step to activate the statutory remedy.
Their subsequent letters in 2000, requesting benefits, were insufficient as they came years after the 60-day period had lapsed without the required conformity. The defense of having complied was contradicted by PNB’s evidence and the Aguilars’ own failure to dispute the recomputation figures. Since the conditions precedent were not met, their right to avail of R.A. 7202 was forfeited. Furthermore, upon finality of the foreclosure and consolidation of title, PNB became the absolute owner of the properties. Its subsequent conveyance to DAR was an exercise of ownership rights, and the Aguilars, having lost all interest in the properties, had no claim to the sales proceeds. The cited compromise agreement in a different case was deemed irrelevant, being a product of mutual concession, not a recognition of a legal right applicable to all.