Deficiency in Foreclosure Sale

Furthermore, we have also ruled in Suico Rattan & Buri Interiors, Inc. v. Court of Appeals that, in deference to the rule that a mortgage is simply a security and cannot be considered payment of an outstanding obligation, the creditor is not barred from recovering the deficiency even if it bought the mortgaged property at the extrajudicial foreclosure sale at a lower price than its market value notwithstanding the fact that said value is more than or equal to the total amount of the debtor’s obligation (Bank of the Philippine Islands, as successor-in-Interest of Far Far East Bank & Trust Company Vs. Cythia L. Reyes,  G.R. No. 182769. February 1, 2012).