Title
Siguion vs. Tecson
Case
G.R. No. L-3430
Decision Date
May 23, 1951
The court upheld the foreclosure of two mortgages, dismissing the defendant's claims related to closed administration, res judicata, payment, and the validity of Republic Act No. 342.
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Case Digest (G.R. No. L-3430)

Facts:

  • Plaintiffs: Paz E. Siguion and her son Alberto Maximo Torres.
  • Defendant: Go Tecson, judicial administrator of Paulino P. Gochecho's estate.
  • Gochecho mortgaged property to Siguion for P30,000 on October 1, 1927.
  • Gochecho later mortgaged the same property to Torres for P20,000.
  • Both mortgages were legally registered.
  • Gochecho died in 1943 without settling the mortgages.
  • Estate settlement initiated in the Court of First Instance of Manila; Tecson appointed as administrator.
  • On February 3, 1949, Siguion and Torres filed for foreclosure against Tecson.
  • Tecson appealed the lower court's ruling, citing:
    • Closed administration proceedings.
    • Res judicata.
    • Claims already paid.
    • Unconstitutionality of Republic Act No. 342.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the plaintiffs, upholding the lower court's decision to allow foreclosure.
  • Tecson could still be sued as administrator; administration proceedings were still pending.
  • Res judicata claim was dismissed due to lack of evidence of prior litigation on mortgage claims.
  • No evidence supported the claim that mortgage debts had...(Unlock)

Ratio:

  • The court clarified that mere suggestions of payment by the administrator did not waive the mortgage lien; no formal claim was filed in intestate proceedings.
  • Res judicata was not applicable due to absence of prior judgment on mortgage claims; necessary documentation was not presented.
  • Lack of credible evidence for alleged pay...continue reading

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