G.R. No. L-10185; November 24, 1915

FACTS:
Angel Gonzalez was appointed chaplain of a collative chaplaincy founded by Doña Petronila de Guzman on August 21, 1901. The chaplaincy’s capital consisted of a building in Binondo, Manila. The administration of the property and its revenues was handled by the administrators of the Sagrada Mitra (the ecclesiastical entity). Gonzalez received annual account settlements and payments from the administrators until December 1906. In September 1909, Gonzalez left the seminary and requested a final settlement of accounts. On November 15, 1910, he executed a document (Exhibit 3) acknowledging receipt of P12,500 from the administrators “as the liquidated balance and in full satisfaction of all revenues that were due or might be due him” from the chaplaincy from October 18, 1901, to December 31, 1910. Subsequently, the Archbishop declared the chaplaincy vacant. Gonzalez later filed a complaint seeking to recover additional income from the property from June 20, 1901, onward and an accounting of revenues for the four years preceding his appointment (1897-1901). The trial court ruled in favor of Gonzalez, ordering the defendants to pay him P19,090.28 and render an account. The defendants appealed.

ISSUE:
1. Whether, after executing a receipt for P12,500 in full satisfaction of all revenues due, Angel Gonzalez is still entitled to collect additional sums from the chaplaincy’s income.
2. Whether the administrators are obligated to render a further accounting of the chaplaincy’s revenues for the period prior to and during Gonzalez’s incumbency.

RULING:
The Supreme Court REVERSED the trial court’s judgment and ABSOLVED the defendants from the complaint.

1. On the claim for additional revenues: The Court held that Gonzalez, by voluntarily signing the receipt (Exhibit 3) acknowledging the P12,500 as full and final settlement, was legally barred from claiming further sums. A settlement presupposes a balancing of accounts, and Gonzalez did not object to the accounts rendered at the time, nor did he prove that his assent was obtained through fraud, deceit, error, or mistake. Under the Code of Civil Procedure, a person is presumed to intend the ordinary consequences of their voluntary acts. Having accepted the payment without protest, Gonzalez explicitly waived any right to additional revenues.

2. On the demand for an accounting: The Court found that accounts for the period from 1897 to December 31, 1900, were already closed and showed a balance of P3,222.67, which was received by Gonzalez in 1901. For the period from 1907 to 1910, although no formal account statement was presented in evidence, the final settlement and receipt in 1910 implied that statements were made and accepted by Gonzalez. Revision of approved accounts is permitted only upon a showing of fraud, error, or mistake, which was not established. Therefore, no further accounting was warranted.

3. On the administration of the property: The Court rejected Gonzalez’s argument that the chaplain should have administered the property personally under the founder’s will. It ruled that after ecclesiastical approval of the chaplaincy, the administration of its property falls under the authority of the Church according to canonical laws, a practice followed since 1863.

Separate Opinions: Justice Moreland, concurring, based his agreement solely on the legal effect of the plaintiff’s receipt (Exhibit 3). Justices Carson and Trent concurred.