Case Digest (A.C. No. 7054) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Salud Patente v. Roman Omega (93 Phil. 218, May 28, 1953), Salud Patente, a single Filipino resident of Villaba, Leyte, sued Roman Omega on a promissory note dated August 24, 1949. The note acknowledged receipt of ₱1,600 “as my indebtedness to her” and stipulated payment “as soon as possible or as soon as I have money,” with no fixed term and without security. Patente obtained a Justice of the Peace (J.P.) decision ordering payment within four months. On appeal to the Leyte Court of First Instance (CFI), the parties filed a compromise of facts presenting two legal questions: (a) whether the J.P. had jurisdiction and could apply Article 1128 of the Civil Code to fix a term; and (b) whether the CFI had appellate jurisdiction. The CFI declared the obligation “pure and unconditional,” ordered payment with interest and costs, and Roman Omega appealed to the Supreme Court.Issues:
- Is the payment term “as soon as possible or as soon as I have money,” lef
Case Digest (A.C. No. 7054) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- The promissory note
- On August 24, 1949, at Villaba, Leyte, Roman Omega signed a promissory note in favor of Salud Patente acknowledging a debt of ₱1,600.
- The note provided payment “as soon as possible or as soon as I have money,” with no fixed term and no security, citing “intimate relations” between families.
- Procedural history
- The Justice of the Peace of Villaba ordered Omega to pay ₱1,600 within four months from promulgation, plus costs.
- On appeal to the Court of First Instance of Leyte, both parties submitted a stipulation of facts and framed two legal questions:
- Whether the Justice of the Peace had jurisdiction to fix a definite term under Article 1128 of the Civil Code.
- Whether the Court of First Instance had appellate jurisdiction.
- The CFI held the obligation pure and unconditional, ordered immediate payment with interest and costs.
- Omega appealed directly to the Supreme Court.
Issues:
- Jurisdiction
- Did the Justice of the Peace of Villaba have jurisdiction to hear the case and apply Article 1128 CC to fix a term?
- Did the Court of First Instance have appellate jurisdiction over the JP’s decision?
- Effect of a payment term left to the debtor’s will
- Is the condition “as soon as possible or as soon as I have money” void under Article 1115 CC?
- Upon nullification of the condition, does the obligation become immediately enforceable, or must the court fix a term under Article 1128 CC?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)