Title
Land Bank of the Philippines vs. Miranda
Case
G.R. No. 220706
Decision Date
Feb 22, 2023
Borrowers failed to complete MRI application; LBP deducted premium, foreclosed property. Court ruled no MRI contract, awarded damages for LBP's wrongful acts.
A

Case Digest (G.R. No. 108854)

Facts:

  • Loan and Mortgage
    • In June–July 1998, petitioner Land Bank of the Philippines (LBP) granted respondent Maria Josefina G. Miranda and her co-borrowers three promissory notes totaling ₱2,400,000.00, secured by a real estate mortgage over TCT No. T-65757.
    • From the first loan release of ₱850,000.00, LBP deducted ₱5,700.82 as a “Mortgage Redemption Insurance” (MRI) premium.
  • MRI Application, Death, and Foreclosure
    • Miranda never accomplished or submitted the MRI application forms; LBP Insurance Brokerage, Inc. (LIBI) did not issue any policy.
    • On August 20, 1998, co-borrower Robert Glenn D. Fox died. Believing the MRI would extinguish the debt, Miranda ceased payments.
    • LBP filed for extrajudicial foreclosure; the property was sold at auction on March 31, 2000 for ₱5,115,904.97, credited against the mortgage debt.
  • Proceedings Below
    • On March 19, 2001, Miranda sued to annul the foreclosure sale, cancel the mortgage and certificate of sale, and recover at least ₱300,000.00 in damages, ₱100,000.00 in attorney’s fees, and costs.
    • The Regional Trial Court (RTC) on June 21, 2010 denied the main relief but awarded Miranda ₱150,000.00 moral damages, ₱5,700.82 reimbursement, ₱100,000.00 attorney’s fees, and costs.
    • The Court of Appeals (CA) on February 24, 2015 affirmed the RTC decision and, on September 28, 2015, denied both parties’ motions for reconsideration.

Issues:

  • Whether LBP is liable for moral damages, attorney’s fees, and costs on the basis that it acted as agent exceeding its authority under Civil Code Article 1897.
  • Whether an MRI contract was perfected and its proceeds applied to extinguish Miranda’s loan upon her co-borrower’s death.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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