Monte de Piedad y Caja de Ahorros de Manila v. Jose Fernando Rodrigo

Summary

This case involved a mortgage foreclosure dispute between Monte de Piedad y Caja de Ahorros de Manila and Jose Fernando Rodrigo over a P15,000 loan secured by multiple properties. After foreclosure judgment of P22,000, two properties sold for P10,000, and Rodrigo paid P7,000 to release the third property in Bulacan. Rodrigo claimed he overpaid P6,000 since his obligation was joint with codefendant Torres, while Monte de Piedad sought to collect an alleged P6,401.50 balance. The Supreme Court En Banc affirmed that Rodrigo's payment was not 'undue' under Civil Code Article 1895, as he was fulfilling his lawful obligation as cosurety. The Court found that the parties' agreement to release the Bulacan property for P7,000 constituted full satisfaction of the mortgage debt, considering the substantial value of the previously foreclosed Manila property and the creditor's delayed action in seeking further collection.