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Case Digest: G.R. No. 47362 - Villaroel vs. Estrada

In the case of Villaroel vs. Estrada, the Supreme Court upheld the enforceability of a debt assumed by Juan F. Villarroel in 1930, despite the original debt having prescribed. The Court ruled that Villarroel's moral obligation as the sole heir of the original debtor constituted sufficient consideration for the new obligation. The ruling clarified that the new obligation was based on Villarroel's voluntary assumption of the debt, not the original debt's prescription.

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9 views2 pages

Case Digest: G.R. No. 47362 - Villaroel vs. Estrada

In the case of Villaroel vs. Estrada, the Supreme Court upheld the enforceability of a debt assumed by Juan F. Villarroel in 1930, despite the original debt having prescribed. The Court ruled that Villarroel's moral obligation as the sole heir of the original debtor constituted sufficient consideration for the new obligation. The ruling clarified that the new obligation was based on Villarroel's voluntary assumption of the debt, not the original debt's prescription.

Uploaded by

Vanesa Lhea
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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Title

Villaroel vs. Estrada

Case Decision Date


G.R. No. 47362 19 Dec 1940

Juan F. Villarroel assumed a prescribed debt in 1930; the Supreme Court


upheld its enforceability, citing moral obligation and voluntary assumption
as valid grounds.

Jur.ph - Case Digest (G.R. No. 47362)


Legal Reasoning Model

Facts:
1. Origins of the Debt: On May 9, 1912, Alejandra F. Callao, the mother of the
defendant Juan F. Villarroel, obtained a loan of P1,000 from the spouses
Mariano Estrada and Severina, payable after seven years (Exhibit A).

2. Death of the Parties: Alejandra F. Callao passed away, leaving Juan F. Villarroel
as her sole heir. The spouses Mariano Estrada and Severina also died, leaving
Bernardino Estrada as their sole heir.

3. Assumption of Debt: On August 9, 1930, Juan F. Villarroel signed a document


(Exhibit B) acknowledging his debt to Bernardino Estrada in the amount of
P1,000, with an annual interest of 12%.

4. Legal Action: Bernardino Estrada !led a case to recover the P1,000 debt,
including interest. The Court of First Instance of Laguna ruled in favor of
Bernardino Estrada, ordering Juan F. Villarroel to pay the amount with 12%
annual interest from August 9, 1930, until full payment.

5. Prescription of Original Debt: The original debt incurred by Alejandra F. Callao


had already prescribed by the time the case was !led. However, the action was
based on the new obligation assumed by Juan F. Villarroel in 1930.

Issue:
(Unlock)

Ruling:
(Unlock)

Ratio:
1. Moral Obligation as Consideration: The Court held that the moral obligation of
Juan F. Villarroel, as the sole heir of the original debtor, was su"cient
consideration to create a new and enforceable obligation.

2. Voluntary Assumption of Debt: The new obligation was not based on the
original debt, which had already prescribed, but on the voluntary assumption of
the debt by Villarroel in 1930.

3. Applicability of Prescription Rules: The rule that a new promise to pay a


prescribed debt must be made by the original debtor or someone legally
authorized by them does not apply in this case. Here, the action was based on
the new obligation voluntarily assumed by Villarroel, not on the original debt.

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