Philippine National Bank vs. Mercedes Corpuz G.R. No. 180945 February 12, 2010 Doctrine
Philippine National Bank vs. Mercedes Corpuz G.R. No. 180945 February 12, 2010 Doctrine
Philippine National Bank vs. Mercedes Corpuz G.R. No. 180945 February 12, 2010 Doctrine
MERCEDES CORPUZ
DOCTRINE:
Banks are expected to be more cautious than ordinary individuals in dealing with lands,
even registered ones, since the business of banks is imbued with public interest.
FACTS:
On October 4, 1974 respondent Mercedez Corpuz delivered her owner’s duplicate copy
of TCT 32815 to Dagupan City Rural Bank as security against any liabilities, then she left her
job and went to the United States. On October 24, 1994 respondent Mercedez Corpuz having
incurred no liability to her employer, the rural bank where she worked cancelled its lien on
Corpuz’s title. However, without Corpuz’s knowledge and consent, Natividad Alano, the rural
bank’s manager, turned over Corpuz’s title to Julia Camacho and Amparo Callejo who connives
with someone from the assessor’s office in preparing a falsifies deed of sale, making it appear
that on February 23, 1995 Corpuz sold her land to one “Mary Bondoc” for P50,000.00. About a
month later the property had been passed to Rufo and Teresa Palaganas by another fictitious
deed of sale by “Mary Bondoc” and after nine (9) days the Palaganas executed a deed of sale in
favor of spouses Virgilio and Elena Songcuan who took out a loan of P1.1 million from
petitioner Philippine National Bank (PNB) who had the title verified and property inspected and,
to secure payment, they executed a real estate mortgage on their title.
ISSUE:
RULING:
No, based on findings in this case is that in the course of its verification, petitioner PNB
was informed of the previous TCTs covering the subject property. It is evident from the faces of
those titles that the ownership of the land changed from Corpuz to Bondoc, from Bondoc to the
Palaganases, and from the Palaganases to the Songcuans in less than three months and
mortgaged to PNB within four months of the last transfer. It would have then discovered that the
property was sold for ridiculously low prices: Corpuz supposedly sold it to Bondoc for just
P50,000.00; Bondoc to the Palaganases for just P15,000.00; and the Palaganases to the
Songcuans also for just P50,000.00. And yet the PNB gave the property an appraised value of
P781,760.00, this significant fact that would create suspicion in an otherwise reasonable person
cannot be considered as an innocent mortgagee for value.