Case Digest (G.R. No. L-2724) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jose de Leon, Cecilio de Leon, and Albina de Leon v. Asuncion Soriano (87 Phil. 193, Aug. 24, 1950), petitioners Jose, Cecilio, and Albina De Leon were the natural children of the late Felix De Leon, and Jose and Cecilio also served as administrators of his intestate estate. Respondent Asuncion Soriano, the decedent’s widow, joined petitioners in a court-approved settlement agreement on March 23, 1943 in the Court of First Instance of Bulacan. Under this pact, petitioners promised to deliver a generic obligation of palay—1,200 cavans in March 1943, 1,400 in March 1944, 1,500 in March 1945, and 1,600 in March 1946 and succeeding years—free of hauling, transport, taxes, or charges, to a designated warehouse in San Miguel, Bulacan. The obligation was to cease upon Soriano’s death and was not transmissible to her heirs, but was secured by a first lien on the estate’s rice lands. Petitioners actually delivered 1,200 cavans in 1943, 700 in 1944, 200 in 1945, and 200 in 1946, fallin... Case Digest (G.R. No. L-2724) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioners Jose de Leon, Cecilio de Leon and Albina de Leon are natural children of the deceased Felix de Leon; respondent Asuncion Soriano is his widow.
- The estate of Felix de Leon was under administration and settlement in the Court of First Instance of Bulacan.
- Settlement Agreement (March 23, 1943)
- The parties entered into an agreement, approved by the probate court, obligating the natural children to deliver annual palay to the widow as follows:
- March 1943: 1,200 cavanes
- March 1944: 1,400 cavanes
- March 1945: 1,500 cavanes
- March 1946 and each succeeding year: 1,600 cavanes
- Delivery was to be at a government or designated warehouse in San Miguel, Bulacan, free of hauling, transportation, taxes or charges; the obligation constituted a first lien on all rice lands of the estate and ceased upon the widow’s death, non-transmissible to heirs.
- Performance and Litigation
- Actual deliveries: 1,200 cavanes in 1943; 700 in 1944; 200 in 1945; 200 in 1946 (total 2,300 cavanes).
- Plaintiff sued for the 3,400-cavan shortage or its cash equivalent (P24,900) plus legal interest.
- Defendants invoked impossibility due to “Huk troubles in Central Luzon,” claiming good-faith delivery of all possible palay.
- Procedural History
- The Court of First Instance ruled for the plaintiff; awarded 3,400 cavanes or P24,900 and interest.
- The Court of Appeals affirmed.
- Petitioners elevated the case to the Supreme Court via certiorari.
Issues:
- 1. Did the failure to deliver the stipulated palay quantities constitute a breach excused by fortuitous events (Huk troubles)?
- Was the palay obligation one for a determinate thing (extinguishable by loss without fault) or for a generic thing (liability remains despite loss)?
- Under Civil Code Article 1182, does loss of generic things without debtor’s fault extinguish the obligation?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)