- Petitioner
- Philippine National Bank
- Respondent
- Spouses Alejandro
- Citation
- G.R. No. 194014
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Velasco, Jr., J.
- Decided
- September 12, 2012
Summary
The Supreme Court reversed lower court decisions that nullified a real estate mortgage over Lot No. 10, finding critical factual errors in their analysis. The case involved spouses Reblando who obtained loans from PNB secured by mortgage over two properties, including Lot No. 10. When they defaulted and PNB foreclosed, the Reblandos challenged the mortgage's validity claiming they weren't owners when it was constituted. The RTC and CA agreed, but the Supreme Court found both parcels were simultaneously mortgaged in 1992 when Alejandro already owned Lot No. 10 per tax declaration issued in 1990. The Court distinguished a 1995 Contract to Sell covering a different property (Unit No. 10 dwelling unit vs. Lot No. 10 land parcel) and applied estoppel principles preventing mortgagors from challenging validity after benefiting from loans. The decision reinforces requirements for mortgage validity under Civil Code Article 2085 while emphasizing estoppel against borrowers who default then challenge security instruments. The Court criticized attempts to mislead courts through incomplete evidence presentation, validating the mortgage and ordering property surrender to the bank.