Case Digest (G.R. No. L-13851)
Detailed and Comprehensive Digest of Malonzo v. Galang
Facts:
- The case involves a loan dispute between Deogracias F. Malonzo (petitioner) and Gregoria T. Galang and her husband Francisco G. Galang (respondents).
- On October 5, 1946, Gregoria received a loan of P5,000.00 from Malonzo, cashed at the National City Bank of New York, Manila.
- On April 17, 1947, Francisco received a loan of P14,968.00 from the Rehabilitation Finance Corporation, endorsed to Malonzo.
- Malonzo cashed the check on April 25, 1947, and applied P10,000.00 to Francisco's fishing venture share, with the remaining P4,968.00 allegedly settling Gregoria's earlier loan.
- Malonzo claimed he returned the P4,968.00 to Francisco, partly in cash and partly via a check for P3,968.00 dated May 19, 1947.
- Believing the loan remained unpaid, Malonzo sued the Galang spouses on August 27, 1955, for the loan amount plus interest and attorney's fees.
- The trial court found in favor of the Galangs, dismissing Malonzo's complaint as unfounded and awarding them P500.00 in compensatory and moral damages, and P1,000.00 in attorney's fees.
- The Court of Appeals affirmed the trial court's decision, prompting Malonzo to appeal to the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court modified the decision by eliminating the award of compensatory and moral damages to the respondents.
- The Supre...(Unlock)
Ratio:
- The award of attorney's fees was deemed correct and proper under Article 2208, paragraph 4 of the Civil Code, which allows for the recovery of attorney's fees in clearly unfounded civil actions.
- Compensatory damages must be duly proved and cannot be presumed; the trial court and the Court of Appeals did not provide specific facts to measure...continue reading
Case Digest (G.R. No. L-13851)
Detailed and Comprehensive Digest of Malonzo v. Galang
Facts: The case of Malonzo v. Galang revolves around a loan dispute between Deogracias F. Malonzo (petitioner) and Gregoria T. Galang and her husband Francisco G. Galang (respondents). On October 5, 1946, Gregoria received a loan of P5,000.00 from Malonzo, which she cashed at the National City Bank of New York, Manila. Subsequently, on April 17, 1947, Francisco received a loan of P14,968.00 from the Rehabilitation Finance Corporation, which he endorsed to Malonzo. Malonzo cashed this check on April 25, 1947, and applied P10,000.00 to Francisco's share in a fishing venture, while the remaining P4,968.00, along with an additional P32.00 in cash, was alleged by the Galangs to have settled Gregoria's earlier loan. Malonzo, however, claimed that he returned the P4,968.00 to Francisco, partly in cash and partly via a check for P3,968.00 dated May 19, 1947. Believing the loan remained unpaid, Malonzo sued the Galang spouses on August 27, 1955, for the loan amount plus interest and attorney's fees. The trial court found in favor of the Galangs, dismissing Malonzo's complaint as clearly unfounded and awarding the Galangs P500.00 in compensatory and moral damages, and P1,000.00 in attorney's fees. On appeal, the Court of Appeals affirmed ...