Case Digest (G.R. No. 37207)
Facts:
The case at hand is Julian T. Aguna v. Antonio Larena, an action brought to recover the total sum of P29,600 from the estate of the deceased Mariano Larena, represented by its Judicial Administrator. The plaintiff, Julian T. Aguna, had two separate causes of action. First, he claimed P9,600, which represented the value of services he allegedly rendered to Mariano Larena as an agent responsible for managing the deceased's properties in Manila from February 1922 to February 1930. During this tenure, Aguna collected rents from tenants and managed repairs on Larena's buildings, without receiving any compensation for his services. The second cause of action involved a claim for P20,000, concerning a building that Aguna constructed with Larena's consent on Larena's land, which Aguna stated was financed by him.
In the lower court, the trial judge ruled that the compensation Aguna was entitled to for his services was covered by the rent-free use of Larena’s property, wh
Case Digest (G.R. No. 37207)
Facts:
- The plaintiff, Julian T. Aguna, brought the action against Antonio Larena, the judicial administrator of the intestate estate of the deceased Mariano Larena, to recover sums amounting to P29,600 under two separate causes of action.
- The first cause of action involved compensation for services allegedly rendered by the plaintiff as the agent in charge of the deceased’s houses in Manila.
- The second cause of action concerned a building claimed by the plaintiff, which he constructed on a parcel of land owned by the deceased, and for which he sought to recover the sums disbursed, totaling P20,000.
Background of the Case
- The record clearly shows that between February 1922 and February 1930, the plaintiff performed various services on behalf of the deceased, including:
- Collection of rents from tenants occupying the deceased’s houses.
- Undertaking necessary repairs and enforcing payment of rents to protect the interests of the deceased.
- During the entire period, the plaintiff did not receive any monetary compensation. Instead, it is admitted that he occupied one of the deceased’s houses rent-free, suggesting that the gratuitous use and occupation of the property may have been an implicit form of payment.
Services Rendered and Compensation Arrangements
- The building in dispute was erected on land belonging to the deceased on Calle Victoria, Manila.
- Construction began in 1926 and was completed in 1928, with the plaintiff financing expenses for materials and labor.
- The ownership and entitlement to the funds invested in the construction came into question.
- The plaintiff claimed that the money invested in the construction was his, based on an alleged understanding with the deceased that upon the latter’s death – occurring intestate – the building (and the money invested in it) would benefit him.
- Evidence supporting this claim included his testimony, that of his witnesses, and documentary evidence such as municipal permits, checks, vouchers, and invoices.
The Construction of the Building
- Exhibit 40, a book of accounts, was presented as evidence showing entries of funds purportedly advanced by the deceased to the plaintiff for the construction of the house.
- The book contained a heading written by the plaintiff and entries spanning from February 1, 1926, to December 31, 1927.
- The total of the entries amounted to P17,834.72, which was nearly equivalent to the alleged amount invested.
- Admissions and Testimony
- The plaintiff admitted having written the heading of Exhibit 40 and acknowledged that some entries (including the receipt of P3,200) were made by him.
- He also admitted that he handed over all receipts of money received from the deceased to be recorded by the latter.
- Corroborative Evidence from Other Exhibits
- Exhibit 41 evidenced corresponding withdrawals by the deceased from his account at the Monte de Piedad.
- Exhibit 43 showed a matching deposit made by the plaintiff in his current account with the Philippine National Bank.
- The cumulative evidence indicated that the funds used for the construction did not belong to the plaintiff.
Documentary Evidence and Admissions
Issue:
- Whether the plaintiff was entitled to claim additional compensation beyond the gratuitous use and occupation of the deceased’s houses, given that he rendered services for eight years without receiving any direct payment.
- Whether the funds advanced by the plaintiff for the construction of the building on the deceased’s land rightfully belonged to him or were to be treated as advances from the deceased as evidenced by the documentary records.
- Whether the plaintiff’s testimony regarding his agreement with the deceased concerning the investment in the building was admissible, considering the prohibition under section 383, paragraph 1, of the Code of Civil Procedure, which restricts an executor or administrator from testifying on events occurring before the decedent’s death.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)