1. Astrid A. Van de Brug vs.

Philippine National Bank;

G.R. No. 207004; June 06, 2018

FACTS:

With the enactment of R.A. 7202, Spouses Aguilar asked PNB for reconsideration of
their account based on the Sugar Restitution Law. PNB required the Spouses to comply
with certain requirements for the granting of the reconsideration. After the subsequent
issuance of the Memorandum of Valuation, the Spouses requested to commence
restructuring of the loan account. The PNB later refused to allow the restructuring of the
account since the Spouses did not formally signify their conformity to PNB's re-computation
of the account.

The RTC ruled in favor of the plaintiff justifying the reconveyance of the lot. On
appeal, the CA reversed the decision, ruling that the Aguilars were not entitled to restitution
absent any excess payment after recomputation. Spouses Aguilar insisted that PNB should
likewise grant them the accommodation made to Spouses Pfleider since they are similarly
situated. On its part, PNB argued that R.A. 7202 only allows restitution if there is an excess
payment on the loan account.

ISSUE:

Whether or not the PNB have an obligation to accord the Aguilars the same
treatment as it accorded the spouses Pfleider?

RULING:

No. the PNB have no obligation to accord the Aguilars the same treatment as it
accorded the spouses Pfleider

Under Article 1157 of the Civil Code the sources of obligations are:

(1) law;
(2) contracts;
(3) quasi-contracts;
(4) acts or omissions punished by law; and
(5) quasi-delicts.

In the case at bar, sources (2), (3) and (4) are inapplicable in this case. The Aguilars
are not privies to the Compromise Agreement between PNB and the spouses Pfleider.
Regarding law, as PNB's source of obligation, the Aguilars are not entitled to restitution
under RA 7202. Thus, RA 7202 cannot be invoked as the statutory basis to compel PNB to
treat the Aguilars similarly with the spouses Pfleider. PNB has explained that there are
differences in the circumstances of its two sugar crop loan debtors which, to PNB, justify the
different accommodations that it accorded to them.

The settlement agreement between PNB and the spouses Pfleider was to the effect
that PNB would credit as payment the CARP proceeds of the foreclosed agricultural
properties in the Compromise Agreement provided that the case filed against PNB was
withdrawn. The Aguilars, on the other hand, did not signify their conformity to the
recomputation as audited and certified by the COA and refused to sign the
restructuring agreement because they insisted that the CARP proceeds be first considered as
loan payments and should be deducted from their loan accounts.

From the Compromise Agreement between the spouses Pfleider and PNB the
accounts of the former to the latter were crop loans and, thus, covered by RA 7202 unlike the
accounts of the Aguilars which included non-RA 7202 accounts. Since the Aguilars were
delinquent in their accounts, PNB had no option but to foreclose the mortgage.