Doronilla v. Gonzaga
REITERATIONFacts
The Antecedents: Plaintiff Ildefonso Doronilla had previously been the tutor of the minor heirs of Pablo Ledesma. After administering their property, a settlement was reached wherein Doronilla became obligated to pay the heirs a certain sum, and in return, he became the owner of uncollected accounts in favor of the estate, including the account that is the subject of the present action. Procedural History: The action was filed in May 1905. The lower court rendered a judgment in favor of the plaintiff for P5,117.55 and costs. The defendant excepted and moved for a new trial, which was denied. The defendant appealed. The Petition: The defendant appealed the lower court's decision, raising three assignments of error concerning the plaintiff's legal capacity to sue, the amount of indebtedness, and the award of interest.
Issue(s)
Whether the plaintiff had the legal capacity to bring the action. Whether the defendant was indebted to the plaintiff in the sum of P3,208.50 as capital. Whether the defendant should be sentenced to pay legal interest on the capital from January 1, 1897.
Ruling
The judgment of the lower court is modified. A judgment is to be entered in favor of the plaintiff and against the defendant for the sum of P3,208.50, with interest at the rate of 6 percent per annum from May 31, 1905, and costs.
Ratio Decidendi
On the plaintiff's legal capacity to sue: The Court affirmed the lower court's finding that the plaintiff had the legal capacity to bring the action. The settlement agreement, by which the plaintiff became the owner of the account in question, was agreed to and accepted by the heirs of Pablo Ledesma and the family council. Even if the president of the family council initially lacked authority, the subsequent actions of the estate's representatives ratified the agreement. The plaintiff, having become the owner of the account through this settlement, was entitled to maintain an action to collect it. On the indebtedness: The Court upheld the lower court's finding that the defendant was indebted to the plaintiff in the sum of P3,208.50. Since the defendant did not bring the evidence to the Supreme Court and had filed a general denial, the appellate court was bound by the lower court's express finding of fact on this matter. On the award of interest: The Court modified the lower court's decision regarding interest. Citing Articles 1755 and 1100 of the Civil Code and Manresa's commentaries, the Court held that interest cannot be collected unless stipulated in the contract or after a judicial or extrajudicial demand has been made. The case record did not show any stipulation for interest or any demand made prior to the commencement of the action in May 1905. Therefore, the plaintiff was only entitled to interest from the date of the judicial demand, which was the filing of the complaint. The judgment was modified to award interest from May 31, 1905.
Main Doctrine
Interest on a debt cannot be collected unless stipulated in the contract or after judicial or extrajudicial demand has been made. The commencement of a civil action constitutes a judicial demand for the purpose of collecting interest.