Ullman v. Hernaez
REITERATIONFacts
The Antecedents: Felix Ullman filed a complaint against Vicente Hernaez to collect a debt of 3,525 Mexican pesos, contracted on April 5, 1900. The debt was to be paid by Hernaez "as soon as I receive the portion that as an heir must come to me from the estate of Juana Espinosa, widow of Hernaez," with interest at six percent per annum, but not compound interest. Procedural History: The Court of First Instance of Occidental Negros initially ruled in favor of Ullman, ordering Hernaez to pay P3,525 with 6% interest from April 5, 1913. Upon a motion for rehearing filed by Ullman, the court amended its decision, ordering Hernaez to pay interest at 6% per annum from April 5, 1900, and costs. Hernaez appealed this amended decision. The Petition: Vicente Hernaez appealed the decision of the Court of First Instance, primarily contesting the trial court's ruling on the prescription of the right of action and the validity of the obligation, arguing that the action had prescribed as it was not exercised from April 5, 1905, until June 2. The appeal was based solely on documentary evidence.
Issue(s)
Whether the action to collect the debt had prescribed. Whether the contract executed by the defendant, who was a minor at the time, was valid or could be ratified.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance, ordering the defendant to pay the plaintiff P3,525 with interest at 6% per annum from April 5, 1900, and costs. The Court found that the action had not prescribed and that the defendant had ratified the contract upon reaching majority.
Ratio Decidendi
On Issue 1: Whether the action to collect the debt had prescribed. The Supreme Court held that the action to collect the debt had not prescribed. The obligation was subject to a suspensive condition: payment was due "as soon as I receive the portion that as an heir must come to me from the estate of Juana Espinosa." According to Article 1125 of the Civil Code, an obligation with a suspensive condition is only enforcible when the day fixed arrives or when the event upon which the obligation depends occurs. The cause of action for the debt only arose when Hernaez ceded his rights to inherit from Juana Espinosa to Rosendo Hernaez on January 25, 1913, for P25,000. This event was equivalent to receiving his share from the estate, thus fulfilling the condition. Therefore, the prescriptive period could not have begun to run before this date, making the suit filed on June 2, 1913, timely. On Issue 2: Whether the contract executed by the defendant, who was a minor at the time, was valid or could be ratified. The Supreme Court found that the defendant's contention regarding his minority at the time of executing the note was without merit. While it was true that Hernaez was three months and fifteen days short of majority when he bought jewelry and executed the note on April 5, 1900, he attained his majority on July 20, 1900. Article 1301 of the Civil Code states that the right of action for nullity of contracts executed by minors or incompetents lasts for four years from the date they were released from guardianship. Hernaez did not attempt to enforce the nullity of the contract either in the year he attained majority or in the four years following. His failure to disaffirm the contract within the prescribed period, coupled with his subsequent actions, constituted an implied ratification of the contract, making it valid and binding.
Main Doctrine
An obligation payable upon the occurrence of a future event, such as the receipt of an inheritance, does not prescribe until that event occurs. The right of action arises only when the condition is met, and any claim of prescription prior to that event is unfounded. Furthermore, a contract entered into by a minor may be ratified upon reaching majority, and failure to disaffirm within the prescriptive period implies ratification.