Title
Tan Tua Sia vs. Yu Biao Sontua
Case
G.R. No. 34533
Decision Date
Mar 31, 1932
Heirs of Sebastian Sontian sued partners over unpaid estate share; promissory note enforced, liability upheld, attorney’s fees reduced.

Case Summary (G.R. No. 34533)

Relevant Transactions

In their amended complaint, the appellees sought to compel payment from the appellants of ₱28,243.40, which included interest and attorney's fees related to the promissory note dated September 21, 1925. This promissory note stated that the sum was payable on or before December 31, 1929, and bore interest at 14% per annum. Defendants Yu Biao Sontua Hnos. y Cia. and Federico Gotua were involved in the failure to pay this debt, leading to the legal action instituted by the plaintiffs.

Court Findings

The trial court found for the plaintiffs, ordering the defendants to pay the principal sum alongside accrued interest and reduced the penalty for attorney's fees to 9% of the principal amount instead of the originally stipulated 20%. Federico Gotua's appeal challenged the trial court’s decision, arguing that he had been misled when signing the promissory note.

Contractual Obligations and Testimony

Gotua claimed that he was deceived regarding the terms of the note at the time of signing. However, the court determined that he was of legal age, engaged in business dealings, and was presumed to have acted with due care in understanding the document he signed. The court placed significant weight on the note’s explicit terms, asserting that Gotua should have read it or sought clarification if he had any doubts.

Established Legal Principles

The decision reaffirmed fundamental legal principles concerning the binding nature of contracts, emphasizing that a signer of a contract is presumed to understand its contents unless evidence of fraud or coercion is presented. The court cited principles from established legal scholarship indicating that a party's failure to read or understand a contract, when able to do so, does not absolve them of the obligations arising from that contract.

Payment of Obligations

The court additionally highlighted that Gotua failed to make any payments towards the principal or interest on the note, even though he claimed that other parties had made payments. This absence of evidence supporting his allegations of payment undermined his position.

Affirmation of Lower Court’s Judgment

Given that all claims of deception or fraud lac

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