Baritua v. Court of Appeals
REITERATIONFacts
1. The Antecedents: On November 7, 1979, a tricycle driven by Bienvenido Nacario collided with a bus driven by petitioner Edgar Bitancor and owned by petitioner Jose Baritua. Bienvenido and his passenger died, and the tricycle was damaged. No criminal case was filed. Subsequently, Bienvenido's widow, Alicia Baracena Vda. de Nacario, received P18,500.00 from the bus insurer, Philippine First Insurance Company, Incorporated (PFICI), in exchange for a "Release of Claim" and an affidavit of desistance, releasing petitioners and PFICI from all claims arising from the accident. 2. Procedural History: On September 2, 1981, the parents of Bienvenido Nacario (private respondents) filed a complaint for damages against petitioners, alleging a promise of indemnification for their son's death, funeral expenses, and the damaged tricycle, which they claimed to have financed. The Regional Trial Court (RTC) dismissed the complaint, holding that the payment to the widow and child, as preferred heirs, extinguished the claim. The Court of Appeals reversed the RTC, ruling that the release executed by the widow did not bar the parents' claim, as they filed the case in their own capacity and the widow could not waive damages she did not suffer. The appellate court also found that the parents had proven they bought the tricycle and shouldered funeral expenses. 3. The Petition: Petitioners sought review of the Court of Appeals' decision, questioning its holding that they were liable for P20,505.00 despite the extrajudicial settlement with the victim's compulsory heirs.
Issue(s)
Whether the Court of Appeals erred in holding the petitioners liable to pay the private respondents despite the extrajudicial settlement and release of claim executed by the victim's widow. Whether the private respondents, as parents of the deceased, are entitled to damages when the deceased's widow and child, as compulsory heirs, have already executed a release of claim; specifically, whether their claims for the purchase price of the tricycle and funeral expenses are valid against the petitioners.
Ruling
The petition is granted. The decision of the Court of Appeals is reversed and set aside, and the decision of the Regional Trial Court is reinstated. Costs against the private respondents.
Ratio Decidendi
On the issue of liability despite extrajudicial settlement: The Court held that obligations are extinguished by payment or performance, as provided by Article 1231 of the Civil Code. The petitioners had indeed paid their obligation arising from the accident. The crucial question was whether Alicia, the widow, was entitled to receive the payment. According to Article 1240 of the Civil Code, payment must be made to the person in whose favor the obligation was constituted, or his successor in interest, or any person authorized to receive it. The Court clarified that under Article 887 of the Civil Code, the widow or widower is a compulsory heir, and in default of legitimate children, parents and ascendants inherit. Since Bienvenido was married to Alicia and they had a child, Alicia and their child were the successors-in-interest and compulsory heirs. Therefore, the private respondents, as parents, were not successors-in-interest and were not compulsory heirs entitled to inherit in the presence of the widow and child. The petitioners acted correctly in settling their obligation with Alicia, the widow and natural guardian of their child, even if she and Bienvenido were estranged, as estrangement is not a legal ground for disqualification. On the claim of the private respondents for expenses: The Court ruled that the private respondents' claims for the purchase price of the tricycle and funeral expenses were money claims against the estate of their deceased son, Bienvenido, and not liabilities of the petitioners. The petitioners had been released from their obligations by the extrajudicial settlement with Alicia, the victim's widow and heir, who executed a "Release Of Claim" in their favor. Thus, the private respondents could not seek relief or compensation from the petitioners for these alleged loans and expenses.
Main Doctrine
An extrajudicial settlement and release of claim executed by the widow and compulsory heir of a deceased, in consideration of payment received, extinguishes the obligation of the party making the payment, even if the deceased's parents also have a claim against the deceased for expenses incurred.