G.R. No. 29416 , October 27, 1928
THE PHILIPPINE NATIONAL BANK, plaintiff-appellee, vs. GREGORIO NIEVA and MARIA A. DE NIEVA, defendants. MARIA A. DE NIEVA, appellant.

FACTS

The Philippine National Bank (PNB) filed a complaint to collect a debt from spouses Gregorio Nieva and Maria A. de Nieva, secured by a mortgage contract (Exhibit A). In the mortgage contract, Maria A. de Nieva expressly stipulated that her liability was limited only to the value of the mortgaged property she owned. The trial court rendered a judgment ordering both defendants to pay the debt. However, in the dispositive portion, it also explicitly stated that Maria A. de Nieva’s liability was limited to the land described in the mortgage deed and that execution for any deficiency after the sale of the mortgaged property could only be issued against the property of Gregorio Nieva. Maria A. de Nieva appealed, arguing that she should not have been sentenced to pay the monetary debt since her obligation was limited by the mortgage contract.

ISSUE

Whether the trial court erred in sentencing Maria A. de Nieva to pay the sum of P164,000, with interest and costs, despite the express limitation of her liability in the mortgage contract to the mortgaged property only.

RULING

No, the trial court did not err. The Supreme Court affirmed the trial court’s decision. While the dispositive portion of the judgment initially ordered both defendants to pay the debt, it was immediately qualified and explained by the subsequent clauses which explicitly limited Maria A. de Nieva’s liability to the mortgaged property. The Court held that when the judgment is read in its entirety, it is clear that Maria A. de Nieva could not be compelled to pay any personal monetary deficiency. Her obligation was strictly confined to the mortgaged property, and any unsatisfied balance after its sale could only be enforced against the property of her husband, Gregorio Nieva. Therefore, the judgment, correctly understood, was in accordance with the terms of the mortgage contract and did not contain the error assigned by the appellant.