Soledad Dalton v. Fgr Realty

Summary

This Supreme Court case established that strict compliance with all Civil Code requirements for valid consignation is mandatory. Soledad Dalton, a tenant, attempted to consign rental payments when landlords refused acceptance, but failed to provide required notice before and after consignation as mandated by Articles 1257-1258. The Court held that substantial compliance is insufficient and that creditors' acceptance of consigned funds with reservations does not waive their right to challenge validity. The case progressed through RTC, Court of Appeals, and Supreme Court, with all courts finding the consignation void. The decision reinforces the principle that consignation procedures must be followed strictly in accordance with Civil Code provisions, and factual determinations regarding payment defaults are not reviewable on appeal under Rule 45.