Case Digest (G.R. No. 176625)
Facts:
On May 9, 1912, Alejandra F. Callao, mother of the present respondent Juan F. Villarroel, obtained a loan of ₱1,000 from spouses Mariano and Severina Estrada (Exhibit A), payable after seven years. Alejandra later died, leaving Juan F. Villarroel as her sole heir. The Estradas also died, leaving their son Bernardino Estrada as their only heir. On August 9, 1930, Juan F. Villarroel executed a written acknowledgment (Exhibit B) declaring that he owed Bernardino Estrada ₱1,000 with 12% annual interest. Bernardino sued in the Court of First Instance of Laguna to collect this amount under the new obligation. The trial court rendered judgment in favor of Bernardino, ordering payment of ₱1,000 with 12% interest per annum from August 9, 1930 until full payment. Juan appealed.Issues:
- Whether, although
Case Digest (G.R. No. 176625)
Facts:
- Original Loan Agreement
- On May 9, 1912, Alejandra F. Callao (mother of respondent Juan F. Villarroel) obtained a loan of ₱1,000 from spouses Mariano Estrada and Severina Estrada, payable after seven years (Exhibit A).
- The spouses Mariano and Severina Estrada likewise died, leaving their son Bernardino Estrada as sole heir.
- Succession of Parties
- Alejandra F. Callao died, and her only heir was her son, the respondent Juan F. Villarroel.
- Mariano and Severina Estrada died, leaving their only heir, the petitioner Bernardino Estrada.
- New Obligation Assumed
- On August 9, 1930, Juan F. Villarroel executed a promissory acknowledgment (Exhibit B), declaring that he owed Bernardino Estrada ₱1,000 with interest at 12% per annum.
- The present action seeks to collect this sum based on Exhibit B.
- Procedural Posture
- The Regional Trial Court of Laguna rendered judgment ordering Villarroel to pay Estrada ₱1,000 with legal interest of 12% per annum from August 9, 1930, until full payment.
- Villarroel appealed the decision to the Supreme Court.
Issues:
- Whether the original debt of ₱1,000, now prescribed, can be enforced by Bernardino Estrada against Juan F. Villarroel.
- Whether the acknowledgment in Exhibit B constitutes a valid new obligation despite the prescription of the original debt.
- Whether a promise to pay a prescribed debt must be made by the original obligor or by someone legally authorized by him.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)