Law on Credit Transactions

​In Planters Development Bank v. Heirs of Delos Santos, the Supreme Court ruled that despite the borrowers’ waiver of demand in the promissory note, the bank was still required to provide personal notice before initiating extrajudicial foreclosure. Failure to do so invalidated the foreclosure proceedings, emphasizing the necessity of proper notification to borrowers. Notwithstanding, the High Court upheld the validity of the foreclosure sale in this case finding that Planters Development Bank complied with its obligation to personally notify Sps. Delos Santos of the same.