Case Digest (G.R. No. 7663)
Facts:
Pedro Martinez v. Matias Cavives et al., G.R. No. 7663. October 20, 1913, the Supreme Court, Trent, J., writing for the Court (Arellano, C.J., Torres, Johnson, Carson, and Moreland, JJ., concur.).
The dispute arose from several promissory notes executed in 1896 by three brothers — Matias Cavives, Severino Cavives, and their now‑deceased brother Carlos Cavives — to Pedro Martinez. The principal joint note (signed by all three) dated April 8, 1896, was for $4,317.15 (Mexican currency) at ten percent interest; Matias separately signed notes for $300 (April 30), $200 (May 30), and $200 (June 7), 1896; Severino signed a note for $600 (June 9), 1896. None of these notes were paid.
On June 14, 1898, Carlos and Pedro executed an instrument (Exhibit 4) purporting to liquidate the 1896 obligations into a new note for $9,483.5 reales, 17 cuartos; Carlos agreed to obtain his brothers' signatures so the instrument would become a joint obligation, but those signatures were never secured. Later, in settling Carlos’s estate, Pedro entered into a compromise with Carlos’s widow by which he accepted P3,000 in full satisfaction and received a note payable in installments (Exhibit 5).
The defendants (Matias and Severino) defended on the ground that the 1898 agreement and subsequent compromise amounted to a novation that extinguished their liability; the trial court accepted that defense and entered judgment accordingly. During the proceedings Robert Lineau, administrator of the estate of Francisco Martinez, intervened claiming the obligations were due to that estate.
The case was brought to the Supreme Court from the court below by appeal; the Supreme Court reviewed whether novation had occurred, whether the intervenor had rights in the notes, and the proper measure of judgment given the Mexican‑to‑Philippine currency issu...(Pro-only)
Issues:
- Did the intervener, Robert Lineau, as administrator of Francisco Martinez’s estate, have a valid claim to the promissory notes so as to supplant or share the plaintiff’s right to recover?
- Did the 1898 instrument between Carlos Cavives and Pedro Martinez, and the subsequent compromise with Carlos’s widow, constitute a novation that extinguished the original obligations of Matias and Severino Cavives?
- Should the case be remanded to the court below to determine the present actual value of Mexican money in Philippine cu...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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