Title
Riobo vs. Hontiveros
Case
G.R. No. 6452
Decision Date
Dec 12, 1911
The court upheld the validity of a public document acknowledging a debt, ruling that a married woman cannot void it for lack of spousal consent.
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Case Digest (G.R. No. 6452)

Facts:

  • Manuel Riobo is the plaintiff and appellant against Ramon Hontiveros and others as defendants and appellants.
  • A public notarial document was executed on March 18, 1897, in Capiz, Province of Capiz.
  • Agustina and Norberta Consolacion acknowledged a debt of P9,190 to Riobo, agreeing to repay in two installments due on July 1, 1898, and July 1, 1899.
  • The sisters mortgaged several parcels of land to secure the debt.
  • Riobo sought P14,519.58, including the original debt and interest, and requested a public auction of the mortgaged properties if payment was not made.
  • Defendants denied the allegations, claiming the document was void due to lack of consideration and that their signatures were obtained through force.
  • They admitted to paying the first installment of P4,595 and counterclaimed for P5,919.50, including Hontiveros' claim of P1,324.50 against Riobo.
  • The trial court found partial payments acknowledged but ruled the mortgage invalid due to lack of property registration, awarding Riobo P5,195 with interest from the complaint date.
  • Both parties appealed the trial court's findings.

Issue:

  • (Unlock)

Ruling:

  • The court affirmed the trial court's finding that the defendants had paid P3,995 on the debt.
  • The court ruled that the plaintiff was not entitled to interest from the date the debt fell due.
  • The court reversed the trial court's ruling regarding the mortgage, finding that the document was duly registered.
  • The cour...(Unlock)

Ratio:

  • The court's decision was based on evidence supporting the defendants' payment of P3,995, corroborated by witness testimonies.
  • The original contract did not stipulate interest, and the plaintiff failed to show he demanded payment before filing the complaint, which is necessary for claiming interest.
  • The court found the trial court erred i...continue reading

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