Case Summary (G.R. No. 6452)

Findings of Fact and Reversal of Trial Court Decisions

• The court generally does not reverse findings of fact made by the trial court unless they are clearly contrary to the weight of the evidence.
• The trial court's findings are upheld unless there is a manifest error.

Validity of Loan Contracts by Married Women

• A married woman can borrow money and execute a guarantee without her husband's consent.
• The husband or his heirs are the only parties who can contest the validity of such a transaction.

Sufficiency of Witness Testimony for Mortgage Registration

• The uncontradicted testimony of a single credible witness can establish the existence of a fact, such as the registration of a mortgage.
• If no objections are raised against this testimony, it should be accepted as valid.

Interest on Debts Without Stipulated Terms

• If a debt instrument does not specify interest, no interest can be claimed unless a demand for payment has been made.
• Interest is only recoverable from the date of filing the complaint if no prior demand was made.

Basis of Plaintiff's Cause of Action

• The plaintiff's claim is based on a public notarial document acknowledging a debt of P9,190 owed by the defendants, Agustina and Norberta Consolacion.
• The defendants agreed to repay the debt in two installments and mortgaged several parcels of land as security.

Defendants' Special Defense and Counterclaim

• The defendants denied the allegations and claimed the document was void due to lack of consideration and alleged coercion.
• They also asserted a counterclaim against the plaintiff for amounts they claimed to have paid and for debts owed to them by the plaintiff.

Trial Court's Findings

• The trial court found that the defendants acknowledged the debt and had made partial payments.
• It ruled that the plaintiff was entitled to interest only from the date of filing the complaint and that the mortgage was not valid due to lack of registration.

Appeals and Errors Claimed by the Parties

• Both parties appealed, with the plaintiff contesting the trial court's findings on payments made, interest entitlement, and the validity of the mortgage.
• The defendants focused their appeal on the validity of the judgment against Agustina Consolacion, arguing the document was void due to lack of her husband's consent.

Evidence of Payments Made

• The trial court's finding that the defendants paid P3,995 was supported by credible witness testimony.
• Testimonies from family members corroborated the payment, despite the absence of a physical receipt due to its destruction.

Interest Recovery and Demand Requirements

• The trial court correctly ruled that the plaintiff could not recover interest prior to filing the complaint due to lack of evidence of demand for payment.
• The plaintiff's vague claims of having made demands were insufficient to establish entitlement to interest.

Motion for New Trial and Evidence Consideration

• The plaintiff's motion for a new trial based on newly discovered evidence was denied as the court found the affidavit insufficient.
• The appellate court could not consider documents not presented in the original trial.

Mortgage Registration and Its Implications

• The trial court failed to adequately consider testimony regarding th...continue reading