GR L 9417; (December, 1914) (Digest)
G.R. No. L-9417, December 4, 1914
PEDRO MARTINEZ, plaintiff-appellee, vs. ANTONINO RAMOS, in his own behalf and as administrator of the estate of his father Julian Ramos, defendant-appellant and ALEJANDRA RAMOS, defendant-appellee.
FACTS:
On May 2, 1900, Antonino Ramos signed a document stating that, by order of his father Julian Ramos, he had received ₱1,900 as an interest-free loan from Pedro Martinez, which he promised to return within three years. After Julian Ramos died, Antonino was appointed judicial administrator of his father’s estate. Pedro Martinez filed a suit against Antonino, both personally and as administrator, to enforce the obligation. The committee on appraisal of the estate initially ruled that the debt was not an obligation of the estate but of the heirs who acknowledged it. Antonino appealed to the Court of First Instance of Batangas, which rendered a judgment holding Antonino personally liable to pay Martinez the reduced sum of ₱1,450 (Mexican currency, converted to Conant at a 30% exchange rate) with legal interest, while absolving the estate of Julian Ramos. Antonino appealed, arguing that subsequent actssuch as transferring the business started with the loan money to his parents and acknowledgment by co-heirsmade the debt chargeable to the estate, not to him personally.
ISSUE:
Whether the obligation under the document signed by Antonino Ramos is his personal debt or a debt chargeable to the estate of his father, Julian Ramos.
RULING:
The Supreme Court affirmed the lower court’s decision, holding Antonino Ramos personally liable. The Court emphasized that under Article 1753 of the Civil Code, a borrower of money acquires ownership of the sum and is obligated to return an equal amount to the lender. The clear terms of the document showed that Antonino alone received the loan and promised to return it. Subsequent agreements or transfers involving Antonino and his co-heirs, to which Martinez was not a party, could not alter the original contract’s force or bind Martinez under the principle that contracts only obligate the contracting parties (Article 1091, Civil Code). Thus, Antonino remained personally bound to fulfill the obligation. The estate of Julian Ramos was correctly absolved from liability. Costs were imposed on the appellant.
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