Case Summary (G.R. No. 173176)
Relevant Dates and Documents
- May 9, 1912: Original loan of P1,000 from Mariano and Severina Estrada to Alejandra F. Callao, payable in seven years (Exhibit A).
- August 9, 1930: Written instrument executed by Juan F. Villarroel acknowledging indebtedness to Bernardino Estrada for P1,000 with 12% annual interest (Exhibit B).
- 1930s: By the time of the suit, the original obligation of Alejandra had prescribed.
Procedural History
Bernardino Estrada sued Juan F. Villarroel in the Court of First Instance of Laguna to recover P1,000 plus interest as stated in Exhibit B. The trial court rendered judgment in favor of Bernardino, ordering Villarroel to pay P1,000 with legal interest at 12% per annum from August 9, 1930 until full payment. Villarroel appealed. The appellate court (Supreme Court) denied the appeal and affirmed the trial court’s judgment, decreeing costs against the appellant.
Factual Background
Alejandra F. Callao obtained the P1,000 loan in 1912 from the Estradas. She died leaving Juan F. Villarroel as her sole heir. The original creditors, Mariano and Severina Estrada, also died, leaving Bernardino Estrada as their sole heir. The original debt had prescribed by the time Bernardino brought the present action. On August 9, 1930, Villarroel executed a written instrument (Exhibit B) acknowledging he owed Bernardino P1,000 with interest at 12% per annum. The present action seeks enforcement of the obligation declared in Exhibit B.
Legal Issue Presented
Whether, despite prescription of the original debt owed by Alejandra, the action to collect the debt is enforceable against Juan F. Villarroel by virtue of the written declaration he executed on August 9, 1930 — i.e., whether Villarroel’s voluntary promise (Exhibit B) created a valid and enforceable obligation notwithstanding prescription of the original obligation.
Court’s Reasoning on Consideration and Effect of Prescription
The Court distinguished between enforcement of the original obligation of the deceased mother and enforcement of the subsequent obligation voluntarily assumed by her heir. Although the original debt had prescribed and thus had lost its enforceability as a legal obligation, the heir (Villarroel) who succeeds to the estate objectively acquires moral ties to that debt. The Court regarded Villarroel’s voluntary assumption of the obligation in Exhibit B as creating a new legal obligation independent of the prescribed original one. The moral obligation of an heir to satisfy a debt that he has inherited was held to supply sufficient consideration for a new promise by that heir to pay; consequently that new promise is enforceable. The Court also clarified that the rule requiring a new promise to pay a prescribed debt to be made by the same person originally bound or by one legally authorized to bind that person does not apply here because the suit is not to revive or enforce the original debtor’s obligation but to enforce a distinct obligation voluntarily undertaken by a different person (the heir).
Application of Law to Facts
Given that Villarroel himself executed Exhibit B acknowledging the P1,000 indebtedness with specified interest, and that this document constituted his voluntary assumption of liability, the Court treated Exhibit B as a valid new obligation. Prescription of the original debt did not bar enforcement of the obligation created by Exhibit B because the latter was not a mere assertion to revive the original obligation but a fresh undertaking by the heir. Accordingly, the respondent was entitled to recover the principal amount and the contractual (legal) interest from the date Villarroel assumed the obligation.
Decision and Disposition
The appellate court denied the appeal and affirmed the judgment of the Court of First Instance of Laguna. Juan F. Villarroel was ordered to pay P1,000 with interest
Case Syllabus (G.R. No. 173176)
Parties and Titles
- Appellant and petitioner: Juan F. Villarroel (recurrente y apelante).
- Appellee and respondent: Bernardino Estrada (recurrido y apelado).
- The parties are, respectively, the sole heirs of the original debtor and of the original creditors, as noted in the record.
Relevant Chronology and Key Facts
- May 9, 1912: Alejandra F. Callao, mother of the defendant (Juan F. Villarroel), obtained from spouses Mariano Estrada and Severina a loan of P1,000, payable after seven years (Exhibit A).
- Subsequent deaths: Alejandra F. Callao died, leaving as her sole heir the defendant (Juan F. Villarroel).
- The spouses Mariano Estrada and Severina also died, leaving as their sole heir the plaintiff (Bernardino Estrada).
- August 9, 1930: The defendant (Juan F. Villarroel) executed a document (Exhibit B) by which he declared himself indebted to the plaintiff (Bernardino Estrada) in the sum of P1,000, with interest at 12 percent per annum.
- The present action is for the collection of the P1,000 declared in Exhibit B, with interest.
Procedural History
- The action was filed in the Court of First Instance of Laguna.
- The trial court condemned the defendant (Juan F. Villarroel) to pay the plaintiff (Bernardino Estrada) the claimed sum of P1,000 with legal interest at 12 percent per annum from August 9, 1930, until full payment.
- An appeal was taken from that judgment.
- The Supreme Court denies the appeal, affirms the appealed judgment, and orders costs against the appellant.
Exhibits and Documentary Evidence
- Exhibit A: The original loan contract dated May 9, 1912, whereby Alejandra F. Callao obtained P1,000 from Mariano Estrada and Severina, payable in seven years.
- Exhibit B: The instrument dated August 9, 1930, whereby the defendant (Juan F. Villarroel) acknowledged indebtedness to the plaintiff (Bernardino Estrada) for P1,000, wi