Title
De Guzman, Jr. vs. Court of Appeals
Case
G.R. No. 92029-30
Decision Date
Dec 20, 1990
Friends dispute settled checks; petitioner claims obligation extinguished, respondent demands payment. Court finds cause of action valid, no prescription, remands for trial.
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Case Digest (G.R. No. 92029-30)

Facts:

  • Relationship Background: Petitioner Nicanor G. De Guzman, Jr. and respondent Enrique KP. Tan were friends who exchanged mutual favors, including discounting checks for cash.
  • Issuance and Settlement of Checks: More than seven years before filing the complaint, petitioner issued several checks totaling ₱280,900 to respondent in exchange for cash. These checks were allegedly fully paid, settled, extinguished, or condoned by mutual agreement.
  • Demand Letter: On August 30, 1988, respondent’s lawyer sent a demand letter to petitioner, claiming ₱568,541 (principal, interest, and attorney’s fees) based on the same checks, threatening legal action if unpaid. Petitioner disputed this, asserting the obligation had been settled.
  • Complaint Filed: Petitioner filed a complaint for damages and equitable reliefs on September 15, 1988, seeking actual, exemplary, and nominal damages, return of the checks, and attorney’s fees.
  • Motion to Dismiss: Respondent filed a motion to dismiss, arguing lack of cause of action and prescription. The trial court dismissed the complaint, and the Court of Appeals upheld this decision.

Issue:

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Ruling:

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Ratio:

  1. Sufficiency of Cause of Action: A cause of action requires two elements: (1) the plaintiff’s primary right and the defendant’s corresponding duty, and (2) the defendant’s wrongful act violating that right. The complaint alleged that petitioner had a right to have the checks returned or canceled since the obligation had been settled, and respondent violated this right by demanding payment for a settled obligation. This constituted a sufficient cause of action.
  2. Prescription: The cause of action accrued on August 30, 1988, when respondent demanded payment for the settled obligation. The complaint, filed on September 15, 1988, was well within the four-year prescriptive period for such actions.


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