Case Digest (G.R. No. 149926) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Union Bank of the Philippines v. Edmund Santibañez and Florence Santibañez Ariola, petitioner Union Bank (successor by assignment of First Countryside Credit Corporation’s assets) sought to collect two promissory notes and a continuing guaranty executed on May 31, 1980 (₱128,000) and December 13, 1980 (₱123,156) by the late Efraim Santibañez, with his son Edmund and respondent Florence as co-makers and guarantors. After Efraim’s death in February 1981, his will was docketed for probate in Iloilo City (Special Proceedings No. 2706), and Edmund was appointed special administrator. On July 22, 1981, Edmund and Florence executed a Joint Agreement partitioning three agricultural tractors inherited from their father and assuming corresponding debts, but without securing probate court approval. In August 1981, FCCC assigned its assets to Union Savings and Mortgage Bank, which petitioner claimed to have succeeded. When respondents failed to pay after demand letters, petitioner filed Case Digest (G.R. No. 149926) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Loan Agreements and Security Instruments
- On May 31, 1980, First Countryside Credit Corporation (FCCC) and Efraim Santibañez entered into a P128,000 loan agreement to purchase one Ford 6600 tractor. Efraim and his son Edmund executed a promissory note payable in five annual instalments starting May 31, 1981.
- On December 13, 1980, FCCC and Efraim entered into a second loan agreement for P123,156 to acquire another Ford 6600 tractor and a Howard Rotamotor. Efraim and Edmund signed a promissory note and a Continuing Guaranty Agreement in favor of FCCC.
- Death, Probate, and Extrajudicial Partition
- February 1981: Efraim died, leaving a holographic will. March 1981: Probate proceedings (Special Proceedings No. 2706) commenced before the RTC of Iloilo City; April 9, 1981: Edmund appointed special administrator.
- July 22, 1981: Edmund and sister Florence executed an extrajudicial Joint Agreement to divide and take possession of the three tractors—two for Edmund, one for Florence—and each to assume the corresponding indebtedness. No probate-court approval was sought.
- Assignment of Credit and Civil Action
- August 20, 1981: FCCC assigned its assets and liabilities to Union Savings and Mortgage Bank (USMB). Petitioner Union Bank of the Philippines (UBP) claimed succession but did not prove it.
- February 5, 1988: UBP filed a complaint for sum of money against heirs Edmund and Florence before RTC Makati, Branch 150 (Civil Case No. 18909). Edmund was not served; action proceeded against Florence only.
- December 7, 1988: Florence filed an answer contending (a) she was not bound by the loan documents, (b) the Joint Agreement was void for lack of probate-court approval, and (c) UBP’s claim should have been filed in probate court.
- Trial and Appeal History
- RTC Makati, Branch 63 dismissed the complaint for lack of merit: (a) claim should have been filed in probate court, (b) Joint Agreement was void as partition before probate, (c) UBP failed to prove succession from USMB.
- Court of Appeals (CA) affirmed: (a) required probate-court claim filing under Rule 86, (b) no valid partition until will probated, (c) participation in ordinary civil case does not waive probate-court rights.
- UBP’s Rule 45 petition assails CA errors regarding (a) approval of Joint Agreement, (b) validity of partition, (c) waiver, (d) heirs’ joint and several liability under guaranty, and (e) promissory notes creating solidary obligation.
Issues:
- Whether an extrajudicial joint agreement partitioning estate assets among heirs is valid without probate-court approval.
- Whether the heirs’ assumption of their father’s indebtedness under the Joint Agreement is binding.
- Whether UBP’s money claim against the deceased should have been filed in the probate court under Rule 86.
- Whether the heirs can be held jointly and severally liable on the Continuing Guaranty Agreement and promissory notes.
- Whether UBP proved its succession to FCCC’s assets and liabilities via assignment.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)