Short answer. Probably not. The Civil Code requires two things for consignation to release a debtor: prior notice to everyone interested, and strict compliance with the rules that regulate payment. Notice alone is not enough — if the consignation was not made strictly in accordance with those payment rules, the law treats it as ineffectual.
What the law says
In order that the consignation of the thing due may release the obligor, it must first be announced to the persons interested in the fulfillment of the obligation.
Civil Code, Article 1257 — Prior Notice of Consignation. Read the full provision →
What the law says
The consignation shall be ineffectual if it is not made strictly in consonance with the provisions which regulate payment.
Civil Code, Article 1257 — Prior Notice of Consignation. Read the full provision →
Two separate requirements, not one
Article 1257 of the Civil Code sets out two distinct requirements for a valid consignation, and both have to be met. The first: in order that the consignation of the thing due may release the obligor, it must first be announced to the persons interested in the fulfillment of the obligation. The second, in the very next sentence, is separate and just as demanding: the consignation shall be ineffectual if it is not made strictly in consonance with the provisions which regulate payment. Satisfying one does not excuse falling short on the other.
Why notifying everyone is not, by itself, enough
Announcing the deposit to the creditor and any other interested parties is meant to give them the chance to object, claim the deposited sum, or otherwise respond before the consignation becomes final. But that notice requirement exists on top of, not instead of, the underlying obligation to actually comply with how payment itself is supposed to be made — the right amount, to the right person or authority, at the right time and place, and following whatever formalities apply to that particular debt. Telling everyone about a deposit that does not otherwise satisfy those payment rules does not cure the defect.
What 'strictly in consonance with the provisions which regulate payment' means
The word strictly is doing real work in this article. It signals that substantial or good-faith compliance with the rules on payment is not the standard — the deposit has to actually conform to those rules. If the underlying payment itself would have been defective, incomplete, offered to the wrong party, or otherwise irregular, depositing that same defective payment in court and giving notice of it does not transform it into a valid consignation. The strict-compliance requirement effectively imports every rule that would have governed a normal, direct payment into the consignation itself.
What this means for your situation
If you gave the required notice but the deposit itself did not follow the rules that would have applied to an ordinary payment of this debt — whether in the amount deposited, who was notified or paid, or the manner of the deposit — Article 1257 treats the consignation as ineffectual, meaning it likely did not release you from the obligation. Since the two requirements are independent, meeting the notice requirement is a necessary step, but it is not, on its own, sufficient to make the consignation valid.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Soledad Dalton vs. FGR Fealty and Development Corporation, et al, G.R. No. 172577, January 19, 2011 — read the decision on LawPhil →
- Limitless Potentials, Inc. vs. The Hon. Reinato G. Quilala, et al, G.R. No. 157391, July 15, 2005 — read the decision on LawPhil →
- Myrna Ramos vs. Susana S. Sarao, et al, G.R. No. 149756, February 11, 2005 — read the decision on LawPhil →