Philippine National Bank v · G.R. 189316

Petitioner: Philippine National Bank
Respondent: Spouses Bernard
Citation: G.R. No. 189316
Court: Supreme Court
Division: First Division
Ponente: Reyes, J.
Decided: July 1, 2013

Summary

PNB mortgaged property using fraudulent title, foreclosed when borrowers defaulted, but true owners Spouses Marañon successfully proved forgery and reclaimed title. Dispute arose over P30,000 rental income paid to PNB by tenant. Supreme Court applied immutability of judgments doctrine to respect RTC's final decision recognizing PNB as mortgagee in good faith with lien on land only. However, since mortgagors weren't true owners, Article 2127 Civil Code provisions on mortgage accessories don't apply to building improvements. Rental income belongs to true property owners (Spouses Marañon) by right of accession, not to PNB despite mortgage lien. Court distinguished between PNB's protected mortgage interest in land versus ownership rights to building-generated rental income.

Statutes applied

Civil Code, Art. 2127

Related cases

Other Philippine cases on the same provisions and issues.

Star Two (Spv-Amc) v. Paper City Corporation of the Philippines G.R. No. 169211
St. Raphael Montessori School v. Bank of the Philippine Islands G.R. No. 184076

By the Intellegal Editorial Board · July 1, 2013

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