Case Digest (G.R. No. L-3435) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Clara Tambunting de Legarda et al. v. Victoria Desbarats Miailhe (substituting William J. B. Burke), G.R. No. L-3435, decided April 28, 1951 under the 1935 Philippine Constitution, plaintiffs Clara Tambunting de Legarda and her husband Vicente L. Legarda sued William J. B. Burke for unjustified refusal to accept payment of their mortgage indebtedness. On June 3, 1944 the complaint alleged that Mrs. Legarda had deposited ₱75,920.83 with the Manila Clerk of Court to discharge a mortgage contracted on February 17, 1926 and renewed several times. Plaintiffs prayed for acceptance of the deposit, issuance of a release of mortgage deed, and ₱1,000 in damages. Burke answered on July 19, 1944, claiming that at a wartime conference (May 26, 1944) he condoned all interest due and to accrue until the end of World War II, in consideration of Mrs. Legarda’s promise to pay only at war’s termination. The trial court initially ordered acceptance of the deposit and release of the mortgage. Bur Case Digest (G.R. No. L-3435) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural History
- June 3, 1944: Plaintiffs file complaint in CFI Manila against William J. B. Burke for refusing to accept payment of a mortgage debt; pray acceptance of ₱75,920.83 deposit, release of mortgage, and ₱1,000 damages.
- July 19, 1944: Burke answers, alleging a May 26, 1944 agreement condoning interest until war’s end in exchange for deferral of payment.
- CFI Decision by Judge Gutierrez David orders Burke to accept the deposit, execute release, and pay costs. Burke moves for new trial (Jan. 14, 1945); liberation intervenes.
- Oct. 23, 1945: Defendant files supplemental answer with counterclaim for foreclosure; Dec. 24, 1945: CFI denies it. Defendant appeals; Supreme Court (GR L-831) orders new trial and remand.
- Remand Proceedings and Judgment
- Mar. 31, 1949: Motion to substitute Victoria Desbarats Miailhe for deceased Burke and to admit amended supplemental answer; granted April 2, 1949.
- April 4, 1949: Plaintiffs reply, denying refusal to accept Japanese notes and claiming debt extinguished by consignation.
- Aug. 5, 1949: CFI (Judge Sanchez) dismisses complaint; orders Clara Tambunting de Legarda to pay ₱70,000 with 3.5% interest from Jan 1, 1942, plus ₱2,500 costs and attorney’s fees; authorizes mortgage sale on default. Plaintiffs appeal.
- Underlying Debt and Wartime Transactions
- Feb. 17, 1926: Original mortgage for ₱75,000 by Clara Tambunting de Legarda (with husband’s consent), due in 5 years; repeatedly extended and interest gradually reduced.
- Mar. 16, 1940: Fourth extension of the remaining ₱70,000 for 3 years; interest lowered from 9% to 7%; option to pay in Philippine pesos or English sterling (₤2 = ₱1).
- Early 1942: Plaintiffs claim a conference where interest was further reduced to 3.5% from Jan 1, 1942; defendant asserts instead a condonation until war’s end.
- May–June 1944: Clara tenders payment in Japanese Military notes via certified check (₱75,920.83); Burke refuses to accept non-legal tender currency. Plaintiffs consign the check in court.
Issues:
- Whether the wartime agreement reduced interest to 3.5% per annum or condoned accrued and future interest until after the war.
- Whether consignation of ₱75,920.83 by certified check in Japanese Military notes validly extinguished the mortgage debt.
- Whether Burke could validly exercise his option to demand payment in English sterling given the outlawing of foreign currencies during occupation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)