Case Digest (G.R. No. 92029-30)
Facts:
The case involves Nicanor G. De Guzman, Jr. as the petitioner and Enrique K.P. Tan as the respondent. The events leading to the case began on September 15, 1988, when De Guzman filed a complaint for damages and other equitable reliefs against Tan in the Regional Trial Court of Manila. The complaint detailed a long-standing friendship between the two parties, during which they exchanged mutual favors, including the discounting of checks for cash. De Guzman alleged that he had issued several checks to Tan over seven years ago, amounting to P280,900.00, which had been fully paid, settled, extinguished, or condoned by mutual agreement. However, on August 30, 1988, De Guzman received a demand letter from Tan's lawyer, claiming that he owed a total of P568,541.00, which included the principal amount, legal interest, and attorney's fees. De Guzman contended that this claim was unfounded and that Tan was wrongfully withholding the checks, which should be returned to him. The ...
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:
- 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.
- 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.