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	GR No. 177729 2011-09-28	PHILIPPINE EXPORT v. AMALGAMATED MANAGEMENT BERSAMIN, J.
In Quirino Gonzales Logging Concessionaire v. Court of Appeals,[29] we have ruled that the 10-year period to recover a deficiency claim starts to run upon the foreclosure of the property mortgaged, viz: With respect to the first to the fifth causes of action, as can be gleaned from the complaint, the Bank seeks the recovery of the deficient amount of the obligation after the foreclosure of the mortgage. Such suit is in the nature of a mortgage action because its purpose is precisely to enforce the mortgage contract. A mortgage action prescribes after ten years from the time the right of action accrued.
	GR No. 135706 2004-10-01	SPS. CESAR A. LARROBIS v. PHILIPPINE VETERANS BANK AUSTRIA-MARTINEZ, J.
In Quirino Gonzales Logging Concessionaire vs. Court of Appeals,[41] we held that the notices of foreclosure sent by the mortgagee to the mortgagor cannot be considered tantamount to written extrajudicial demands, which may validly interrupt the running of the prescriptive period, where it does not appear from the records that the notes are covered by the mortgage contract.[42]