Case Digest (G.R. No. L-4871)
Facts:
The case involves Ang Lam, the appellant and creditor, against Hilario Peregrina, the special administrator and appellee, concerning the intestate estate of Eugenia Peregrina, who passed away on April 1, 1945. On December 26, 1944, Eugenia Peregrina borrowed P100,000 from Ang Lam, with a promise to repay the amount within one year. Following her death, Ang Lam filed a claim against her estate for the full amount of the loan. The lower court rendered a judgment awarding Ang Lam only P1,000, which was determined using the Ballantyne Conversion Table. Ang Lam appealed this decision, arguing that since the contract did not specify the currency for repayment, the debt should be settled in the legal tender available on December 25, 1945, one year after the loan was made. He contended that both parties had implicitly agreed to the risk of currency fluctuations, which should allow for the repayment in the currency's value at t...
Case Digest (G.R. No. L-4871)
Facts:
- Loan Agreement: On December 26, 1944, Eugenia Peregrina borrowed P100,000 from Ang Lam, with the promise to repay the amount within one year.
- Death of Debtor: Eugenia Peregrina passed away on April 1, 1945.
- Claim Against Estate: Ang Lam filed a claim against Peregrina's estate for the full amount of the loan.
- Judgment: The court ruled in favor of Ang Lam but awarded only P1,000, based on the Ballantyne Conversion Table, which adjusted the value of the loan to the currency in effect at the time of payment.
- Appeal: Ang Lam appealed, arguing that the loan should be paid in the legal tender existing on December 25, 1945, as the parties had implicitly agreed to subject their rights to the contingency of currency fluctuation.
Issue:
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Ruling:
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Ratio:
- No Presumption of Contingency: The court held that there was no evidence to support the presumption that the parties intended to subject their rights and obligations to the contingency of currency fluctuation.
- Fairness and Justice: The court emphasized that it would be unjust to allow the lender to be unduly enriched by requiring payment in the restored currency at the same nominal amount. Conversely, it would also be unfair to the debtor to require payment in the original currency if its value had significantly depreciated.
- Doctrine of Equivalence: The court applied the doctrine of equivalence, as established in Hilado vs. De la Costa and Thorington vs. Smith, which requires that the debtor pay the actual value of the loan at the time it was contracted, using the currency in effect at the time of payment.
- Precedent: The court cited similar cases (Gomez vs. Tabia and Rono vs. Gomez) where obligations were payable in the currency existing at the time of payment, not at the time the obligation was incurred.