Sunday, July 9, 2023

Case Digest: Lopez Vito vs Tambunting, 33 Phil 226

Lopez Vito vs Tambunting, 33 Phil 226

Subject: Obligations and Contracts

FACTS

These proceedings were brought to recover from the defendant the sum of P2,000, amount of the fees, which, according to the complaint, are owing for professional medical services rendered by the plaintiff to a daughter of the defendant from March 10 to July 15, 1913, which fees the defendant refused to pay, notwithstanding the demands therefor made upon him by the plaintiff.

The defendant denied the allegations of the complaint, and furthermore alleged that the obligation which the plaintiff endeavored to compel him to fulfill was already extinguished.

The court after discussing the matter of the service rendered and after taking into account that the plaintiff, as soon as he had finished rendering them, asked for compensation in the sum of P700 only, and furthermore, holding that it was in no wise proven that, because said amount was not paid the plaintiff was entitled to recover from the defendant, by means of these proceedings, the sum of P2,000, held that the reasonable value of said services could only be worth said P700.

The receipt signed by the plaintiff, for P700, the amount of his fees he endeavored to collect from the defendant after he had finished rendering the services in question (which receipt was presented by the defendant at the trial as Exhibit 1) was in the latter's possession, and this fact was alleged by him as proof that he had already paid said fees to the plaintiff.

ISSUE

Whether or not implied condonation can be legally presumed in the instant case?

RULING

No.

Article 1271 of the New Civil Code provides that the delivery of a private document evidencing a credit, made voluntarily by the creditor to the debtor, implies the renunciation of the action which the former had against the latter. And article 1272 prescribes that whenever the private document in which the debt appears is found in the possession of the debtor, it shall be presumed that the creditor delivered it voluntarily, unless the contrary is proved. 

In the present case, it cannot be said that these circumstances concurred, inasmuch as when the plaintiff sent the receipt to the defendant for the purpose of collecting his fee, it was not his intention that that document should remain in the possession of the defendant if the latter did not forthwith pay the amount specified therein.

No comments:

Post a Comment

Case Digest: General Santos Coca-Cola Plant Free Workers Union – TUPAS vs Coca-Cola Bottlers Philippines., Inc., CA and NLRC, G.R. No. 178647

  General Santos Coca-Cola Plant Free Workers Union – TUPAS vs Coca-Cola Bottlers Philippines., Inc., CA and NLRC,  G.R. No. 178647,  Februa...