De Leon v. Soriano
REITERATIONFacts
The Antecedents: Petitioners, natural children of the deceased Felix de Leon, and respondent, his widow, entered into an agreement approved by the probate court. The agreement stipulated that the natural children would deliver specific quantities of palay annually to the widow, commencing in March 1943 and continuing until her death. The obligation was to constitute a first lien on the estate's rice lands. The natural children made partial deliveries from 1943 to 1946, falling short of the agreed quantities by 3,400 cavanes. Procedural History: The widow filed an action to recover the shortage or its value. The defendants (natural children) averred that their failure to deliver the full amounts was due to the "Huk troubles in Central Luzon," rendering full compliance impossible. They contended that their obligation was dependent on the produce and that they had fulfilled it in good faith by delivering all that was possible under the circumstances, characterizing the obligation as an annuity. The Petition: The Court of First Instance rendered judgment for the plaintiff, ordering the defendants to deliver the shortage of palay or its cash equivalent with legal interest. This judgment was affirmed by the Court of Appeals. The case reached the Supreme Court on appeal by certiorari.
Issue(s)
Whether the petitioners' obligation to deliver the stipulated quantity of palay was extinguished by the 'Huk troubles' and resulting crop failure. Whether the palay subject of the agreement constitutes a determinate or generic thing.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals. The petitioners were ordered to deliver the shortage of 3,400 cavanes of palay or its equivalent in cash, plus legal interest.
Ratio Decidendi
On Issue 1: The Supreme Court held that the obligation was not extinguished because the subject matter of the contract—palay—is a generic thing. Applying Article 1182 of the old Civil Code, the Court explained that while the loss of a determinate thing without fault on the part of the debtor extinguishes the obligation, the same is not true for generic things. The Court invoked the maxim 'genus nunquam perit' (the genus never perishes), signifying that as long as the thing belongs to a genus, its loss does not relieve the debtor of the duty to perform. The petitioners' failure to harvest enough palay due to insurgency or weather did not render the obligation naturally impossible, but merely constituted a subjective inability to perform. Therefore, the risk of being able to procure the palay from other sources remained with the petitioners, who could have provided for such contingencies in the contract. On Issue 2: The Court ruled that the palay promised was a generic thing because the contract set no bounds or limits to the cereal to be paid. There was no specific stipulation that the palay must be the produce of any particular land owned by the estate or the petitioners. Any palay of the quality stipulated, regardless of its origin, would have been sufficient to discharge the obligation. Citing Manresa, the Court defined a generic thing as one whose determination is confined to its nature or genus, such as a horse or a chair, as opposed to a concrete object with its own individuality. Since the palay had not been segregated or specifically identified at the time of the agreement, the 'Huk troubles' affecting the petitioners' local harvest did not affect the existence of the genus and thus did not extinguish the debt.
Main Doctrine
The obligation to deliver a generic thing is not extinguished by the loss of a specific item, even if such loss is due to a fortuitous event, as the genus never perishes. Performance is not excused by subsequent inability to perform, unforeseen difficulties, or unusual expenses, unless the impossibility is inherent in the nature of the thing itself and not merely in the obligor's ability to perform.