Who should prove deficiency or excess in foreclosure sale?

[1] Resort Hotels Corporation v. Development Bank of the Philippines, G.R. No. 180439 December 23, 2009, 609 SCRA 16; citing Homeowners Savings and Loan Bank v. Dailo, G.R. No. 153802, March 11, 2005.
[2] G.R. No. 200567, June 22, 2015.
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