Case Digest (G.R. No. 229103)
Facts:
In Rosario L. de Braganza, et al. vs. Fernando F. de Villa Abrille, G.R. No. L-12471, decided on April 13, 1959, the respondent, Fernando F. de Villa Abrille, advanced ₱70,000 in Japanese war notes to petitioners Rosario L. de Braganza and her sons, Rodolfo and Guillermo, on October 30, 1944. In return, the Braganzas executed a promissory note (Exhibit A) promising to pay ₱10,000 in Philippine currency “two years after the cessation of the present hostilities or as soon as International Exchange has been established in the Philippines,” plus 2% annual interest. At that time, Guillermo and Rodolfo were minors, aged 16 and 18 respectively. In March 1949, upon non-payment, Abrille sued for the stipulated amount with interest. In their answer before the Court of First Instance of Manila, the Braganzas contended they only received ₱40,000, and asserted the defense of minority for the two sons. The trial court rendered judgment for Abrille, which was affirmed by the Court of Appeals,Case Digest (G.R. No. 229103)
Facts:
- Loan Transaction
- On October 30, 1944, petitioners Rosario L. de Braganza and her sons Rodolfo (18 years old) and Guillermo (16 years old) received from respondent Fernando F. de Villa Abrille a loan of ₱70,000 in Japanese war notes.
- In consideration thereof, they executed a promissory note (Exhibit A) promising to pay ₱10,000 in Philippine legal currency two years after the cessation of hostilities or upon establishment of international exchange in the Philippines, plus 2% interest per annum.
- Trial and Appeal
- When payment did not materialize, Villa Abrille sued petitioners in March 1949 before the Manila Court of First Instance. Petitioners answered, alleging they only received ₱40,000 and that Guillermo and Rodolfo were minors at the time of signing Exhibit A.
- The trial court rendered judgment in favor of Villa Abrille for ₱10,000 plus 2% interest from October 30, 1944. The Court of Appeals affirmed, holding all three petitioners solidarily liable.
Issues:
- Capacity and Liability of Minors
- Can Rodolfo and Guillermo, as minors, be bound by Exhibit A?
- Does their failure to disclose minority constitute fraud sufficient to enforce the promissory note?
- Timeliness of Raising Minority
- Is the defense of minority barred by the four-year period under Article 1301 of the Civil Code, given that Rodolfo reached majority in October 1947 and the defense was interposed in June 1951?
- Extent of Liability
- To what extent are the minors and Rosario L. de Braganza liable—whether under Exhibit A or by restitution for benefits received?
- What interest rates apply and from what dates?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)