Case Digest (G.R. No. L-6220)
Facts:
In Quizana v. Redugerio, plaintiff-appellee Martina Quizana, a widow residing in Hupi, Sta. Cruz, Marinduque, sued defendants-appellants Gaudencio Redugerio and Josefa Postrado for P550 with interest, based on a written obligation executed on October 4, 1948. Under this agreement the spouses acknowledged receipt of P550 on the condition that it be repaid by January 31, 1949, and, in default, that they would pledge a parcel of land in Barrio Balogo, Santa Cruz, Marinduque, as mortgage security. The justice of the peace rendered judgment for Quizana, and on appeal the Court of First Instance denied the appellants’ “Urgent Motion for Continuance,” heard only plaintiff’s evidence in their absence, and again ruled for Quizana. The Court of First Instance also denied the appellants’ motion for reconsideration on the ground of deprivation of their day in court. The Supreme Court granted the defendants-appellants’ appeal to resolve the nature and binding effect of the second pa...Case Digest (G.R. No. L-6220)
Facts:
- Parties and Instrument
- Plaintiff-Appellee: Martina Quizana, a widow residing in Hupi, Sta. Cruz, Marinduque.
- Defendants-Appellants: Spouses Gaudencio Redugerio and Josefa Postrado.
- Loan Agreement (October 4, 1948)
- The spouses acknowledged a P550 loan from Quizana, payable “at the end of January 1949.”
- They further agreed that, if they failed to pay on time, they would pledge a parcel of land in Cororocho, Balogo, Sta. Cruz, Marinduque (with metes and bounds), by executing and delivering a mortgage deed to Quizana.
- Proceedings Below
- Justice of the Peace Court (Sta. Cruz)
- Quizana sued on the actionable document; the J.P. rendered judgment for P550 with interest.
- Defendants appealed, asserting as special defense that they offered to execute the mortgage deed on January 31, 1949, but Quizana refused.
- Court of First Instance (Marinduque)
- Case set for hearing on August 16, 1951. On July 30, defendants filed an “Urgent Motion for Continuance,” which was not resolved until trial day.
- On August 16, the CFI denied the continuance, heard only Quizana’s evidence in defendants’ absence, and affirmed the P550 award with interest.
- Defendants’ motion for reconsideration—alleging deprivation of their day in court—was likewise denied.
- Appeal to the Supreme Court followed from (a) the CFI’s judgment for P550 plus interest and (b) denial of reconsideration.
Issues:
- Whether the second part of the written obligation—pledging a mortgage in lieu of payment (a facultative obligation)—is valid and binding on the plaintiff-appellee.
- Whether the plaintiff’s acceptance of the unprotested document binds him to all its terms, including the mortgage clause.
- Whether the denial of the defendants’ motion for continuance and reconsideration deprived them of their day in court (although SC did not find it necessary to resolve this).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)