Juanita T. Sering v. Court of Appeals

Summary

Juanita Sering mortgaged her property to Clarita Garcia for a P200,000 loan but failed to make payments despite multiple demands. Garcia proceeded with extrajudicial foreclosure in 1993. Sering filed suit claiming she had already paid the loan but Garcia refused to issue receipts, and that the actual loan was only P100,000. The Regional Trial Court dismissed her complaint, which was affirmed by the Court of Appeals and Supreme Court. The Supreme Court ruled this was a factual issue beyond the scope of certiorari review, emphasizing that debtors should use legal consignation under the Civil Code when creditors refuse to issue payment receipts, rather than claiming unsubstantiated payments. The decision upheld the validity of the foreclosure proceedings and established the principle that proper legal remedies exist when creditors refuse to acknowledge payments.