G.R. No. 47414 - Pablo vs. Sapungan

On July 30, 1924, Ambrosio Sapungan signed a document (Exhibito A) acknowledging his obligation to pay the plaintiffs the amount of P1,519.49 in three installments, together with legal interest.
This document served as the original basis for the claim against him.

On May 21, 1930, when the plaintiffs filed a case to collect the debt, a further agreement (Exhibito 6) was reached between the parties.
In this agreement, the defendant reacknowledged that he owed the plaintiffs the sum of P1,519.49, which represented the value of the legacies the plaintiffs were entitled to over a parcel of land inherited from the late Severina Ruedas de Pablo—a parcel subsequently purchased by the defendant.
The agreement explicitly noted that the defendant had not been making payments due to an ongoing litigation with Padre Pajarillo concerning the same piece of land.

In another case addressing the claims of Padre Pajarillo on the same property, both parties entered into another agreement wherein the defendant committed to registering the title within six months.
The failure of the defendant to either pay the acknowledged amount or to secure the registration within the stipulated period led to the initiation of the current action by the plaintiffs for the recovery of P1,519.49.

The Regional Trial Court in Tayabas issued a decision condemning Ambrosio Sapungan to pay the plaintiffs the sum of P1,519.49 along with legal interest from July 30, 1924, until full payment was effected.
Considering that the amount was linked to the sale price of a land still embroiled in litigation with a third party, the court invoked Article 1502 of the Civil Code.
Accordingly, it ordered the plaintiffs to post a bond (fianza) in the amount of P1,520. This bond was meant to secure the defendant's right to a refund of the price should he prevail in the pending litigation.

The defendant challenged the trial court’s imposition of interest, arguing that the initial obligation in Exhibito A to pay interest had been effectively replaced by the terms of the subsequent agreement (Exhibito 6), which made no explicit mention of interest.
He also objected to the requirement that the plaintiffs post a bond in the amount of P1,520, contending that such a condition was an error.

Whether the defendant’s obligation to pay legal interest on the amount of P1,519.49 survives despite the subsequent agreement (Exhibito 6) which did not expressly mandate the payment of interest.
Whether the reiteration of the debt in Exhibito 6 constitutes a novation of the original contract, thereby extinguishing the obligation to pay interest noted in Exhibito A.

Whether the trial court erred in requiring the plaintiffs to post a bond amounting to P1,520 to secure the defendant's refund right on the land sale price under Article 1502 of the Civil Code.
If the set amount was consistent with the statutory provision and the circumstances of the case.