Case Digest (G.R. No. L-3561)
Facts:
- The case involves a financial dispute during the Japanese occupation of the Philippines.
- On October 1, 1942, Dr. Cesar Reyes loaned P6,500 to Agripino Zaballero and others.
- The loan was secured by a first mortgage on ten parcels of land in Lucena, Quezon Province.
- The loan agreement required annual installments of P650, payable in Philippine or U.S. currency, with 10% interest per annum.
- Installments for 1942 and 1943 were paid in Japanese military notes, which Reyes accepted without reservations.
- In 1944, Reyes refused to accept Japanese military notes for the third installment due to their devaluation.
- Despite Reyes' refusal, Exequiel Zaballero tendered the remaining balance of P5,812 in Japanese military notes on December 1, 1944.
- Reyes, on his attorney's advice, accepted the payment and executed a notarial deed of release for the mortgage.
- Reyes later executed an affidavit stating he accepted the payment under protest and deposited the money in a special account.
- Reyes filed a lawsuit to recover the debt, claiming his acceptance was invalidated by duress.
- The Court of Appeals ruled the payment was valid and the debt was discharged, leading Reyes to appeal to the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the acceptance of Japanese military notes by Dr. Cesar Reyes was not invalidated by duress.
- The Supreme Court affirmed that the dischar...(Unlock)
Ratio:
- The Supreme Court concluded that Dr. Cesar Reyes' acceptance of the payment was voluntary, even if reluctant.
- The Court of Appeals found no evidence of duress or intimidation that would invalidate the payment.
- According to the Civil Code, duress or intimidation exists when a contracting party is driven by a rational and well-grounded fear of imminent and serious injury to their person or property, or to the person or property of their spouse, descendants, or ascendants.
- The Court of Appeals found no credible evidence that Reyes was threatened into accepting the payment.
- Reyes' testimony about the debtor's menacing attitude was discredited, and his affidavit stating he accepted the ...continue reading
Case Digest (G.R. No. L-3561)
Facts:
The case of Reyes v. Zaballero revolves around a financial dispute during the Japanese occupation of the Philippines. On October 1, 1942, Dr. Cesar Reyes, the petitioner-appellant, loaned P6,500 to the respondents-appellees, Agripino Zaballero and others. This loan was secured by a first mortgage on ten parcels of land located in Lucena, Quezon Province. The loan agreement stipulated annual installments of P650, payable in Philippine currency or its equivalent in U.S. currency, at the creditor's discretion, with interest payable in advance at a rate of 10% per annum. The installments for the years 1942 and 1943 were paid in Japanese military notes, which Reyes accepted without any reservations. However, when the third installment was due in 1944, Reyes refused to accept payment in Japanese military notes, citing their devaluation and his contractual right to demand payment in Philippine or U.S. currency. Despite Reyes' refusal, Exequiel Zaballero, one of the debtors, tendered the entire remaining balance of P5,812 in Japanese military notes on December 1, 1944. Acting on his attorney's advice, Reyes accepted the payment and executed a notarial deed of release for the mortgage. Subsequently, Reyes secretly executed an affidavit stating that he accepted the payment under protest and deposited the money in a special account at the Philippine National Bank. Reyes later filed a lawsuit seeking recovery of the debt, arguing that h...