Petitioner
United Coconut Planters Bank
Respondent
Spouses Samuel
Citation
G.R. No. 159912
Court
Supreme Court
Division
Third Division
Ponente
Chico-Nazario, J.
Decided
August 17, 2007

Summary

This Supreme Court case involved a commercial banking dispute between United Coconut Planters Bank and the Beluso spouses over the validity of interest rate provisions in promissory notes. The spouses borrowed up to P2.35 million under a credit line secured by real estate mortgage. The promissory notes allowed UCPB to unilaterally determine interest rates, which the Supreme Court found violative of the Civil Code's principle of mutuality of contracts. While affirming that the interest provisions were void, the SC modified the lower courts' computation by imposing 12% legal interest and reducing unconscionable penalties from 30-36% to 12%. The Court also upheld UCPB's liability under the Truth in Lending Act for failing to properly disclose finance charges before consummation. The foreclosure was declared valid since a proper demand was made, though excessive. This case establishes important precedent on banking contract validity, unconscionable penalties, and Truth in Lending Act compliance in Philippine commercial law.

Statutes applied

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By the Intellegal Editorial Board · August 17, 2007

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