Case Digest (G.R. No. 82233)
Facts:
Petitioners Jose Baritua and Edgar Bitancor operated JB Bus No. 80 which on November 7, 1979 collided with a tricycle driven by Bienvenido Nacario at Barangay San Cayetano, Baao, Camarines Sur; Bienvenido and his passenger died and the tricycle was damaged. On March 27, 1980 the petitioners and the insurer PFICI paid Alicia Baracena Vda. de Nacario P18,500 and obtained a Release Of Claim and an affidavit of desistance; on September 2, 1981 private respondents Nicolas Nacario and Victoria Ronda Nacario, parents of the deceased, sued the petitioners for damages, the RTC dismissed their complaint, the Court of Appeals reversed and awarded P20,505, and the petitioners sought review here.
Issues:
- Did the Court of Appeals err in holding that the petitioners remained liable to the private respondents despite the extrajudicial settlement between the petitioners and the victim's compulsory heirs?
- Could Alicia Baracena Vda. de Nacario, as widow and co-heir, validly receive payment and execute a release that extinguished the petitioners' obligation?
Ruling:
The petition was granted. The Court reversed and set aside the decision of the Court of Appeals and reinstated the judgment of the Regional Trial Court dismissing the private respondents' complaint, with costs against the private respondents.
Ratio:
The Court held that obligations are extinguished by payment under Article 1231, Civil Code, and that payment to the person in whose favor the obligation was constituted or to a successor in interest validly extinguishes the obligation under Article 1240, Civil Code. Because Alicia was the surviving spouse and the mother of the deceased's child, she and the child were compulsory heirs within Article 887, Civil Code, and parents succeed only in default of descendants under Article 985, Civil Code; estrangement did not disqualify her. The parents' expenditures were money claims against the estate, not liabilities of the petitioners once the widow, as co-heir, executed the release that extinguished the petitioners' liability.
Doctrine:
- Article 1231, Civil Code: payment extinguishes obligations.
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