Title
Baer Senior and Co's Successors vs. Mendoza
Case
G.R. No. L-5778
Decision Date
Jan 7, 1911
Plaintiffs claimed P3,656.66 from defendant, who admitted owing P2,827.28 but contested P829.38 interest. Court ruled P500 deduction and 3% commission were unconditional, reducing debt to P2,242.47; interest claim rejected due to lack of evidence.
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Case Digest (G.R. No. L-5778)

Facts:

  1. Parties Involved:

    • Plaintiffs: Baer Senior & Co's. Successors
    • Defendant: Francisco Mendoza
  2. Nature of the Case:

    • The plaintiffs demanded payment from the defendant for a balance of an account-current amounting to P3,656.66.
  3. Defendant’s Admission:

    • The defendant admitted owing the principal amount of P2,827.28 but contested the payment of interest amounting to P829.38.
  4. Agreements and Deductions:

    • The plaintiffs agreed to deduct P500 from the principal due to losses suffered by the defendant from a fire, reducing the principal to P2,327.28.
    • It was stipulated that the defendant was entitled to a 3% commission on the principal (P2,827.28), amounting to P84.81, further reducing the amount owed to P2,242.47.
  5. Trial Court Decision:

    • The Court of First Instance of Manila ordered the defendant to pay P2,742.47 with 6% legal interest from March 30, 1909, until full payment, plus costs.
  6. Defendant’s Appeal:

    • The defendant appealed, arguing that the P500 deduction was unconditional and not contingent on paying interest.
    • He relied on Exhibit A, a letter from the plaintiffs, which he claimed proved the unconditional nature of the deduction.
  7. Exhibit A:

    • The plaintiffs acknowledged the P500 deduction but stated they would collect interest on the balance from January 1, 1907, based on a verbal agreement and exchanged letters.
    • The defendant denied any agreement or correspondence regarding interest.

Issue:

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Ruling:

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Ratio:

  1. Interpretation of Agreements:

    • The court emphasized that the P500 deduction must be interpreted as unconditional, as there was no evidence to support the plaintiffs’ claim that it was contingent on the payment of interest.
  2. Burden of Proof:

    • The plaintiffs failed to provide sufficient evidence (e.g., a verbal agreement or written correspondence) to prove that the defendant agreed to pay interest on the balance.
  3. Legal Principles:

    • Deductions and agreements must be clearly established and supported by evidence. Ambiguities in contracts are resolved against the party seeking to enforce them.
  4. Final Amount Owed:

    • After deducting the P500 and the 3% commission, the defendant was only liable to pay P2,242.47.


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