Facts: This case revolves around the claims made by Epifanio M. Longara against the intestate estate of Fernando Hermosa, Sr. There are three separate claims totaling P18,037.53 for credit advances provided by Longara to Hermosa Sr., Hermosa’s son Francisco, and grandson Fernando Hermosa, Jr. over varying periods. Hermosa Sr. had made a promise that the repayment of these advances would occur when he received the funds from the sale of his property in Spain. Following Hermosa Sr.’s death in December 1944, the administratrix and widow of Hermosa sold the property in November 1947 and received the proceeds. The claim was filed by Longara on October 2, 1948. The Court of Appeals upheld Longara’s claims, resulting in the heirs filing for certiorari with the Supreme Court citing the condition for repayment as potestatively contingent on Hermosa Sr.’s will, thus null and void.
Procedural Posture: Longara presented evidence substantiating his claims for credit advances provided to Hermosa Sr. and his descendants. The Court of Appeals found in favor of Longara, and its decision was contested by Hermosa’s heirs in the Supreme Court through an appeal by way of certiorari.
Issues:
1. Whether the condition for the repayment of the credit advances (“as soon as he [intestate] receives funds derived from the sale of his property in Spain”) is a potestative condition and thus null and void.
2. Whether the claims furnished to the intestate’s grandson after Hermosa Sr.’s death should be allowed.
3. Whether the claims are barred by the statute of non-claims since they were not raised in the lower courts.
Court’s Decision:
1. The Supreme Court held that the condition for repayment was not exclusively potestative, but rather a mixed condition that partly depended upon the intestate’s will and partly on chance, such as the presence of a willing buyer. Therefore, the condition was valid, and the obligations became due upon the sale of the Spanish property.
2. The claims furnished to Hermosa’s grandson after his death were not allowed as the obligation to furnish support is personal, thus extinguishing upon death, and an agent’s authority ceases with the principal’s death.
3. As the statute of non-claims was not brought up in earlier courts, the Supreme Court declined to rule on this issue at the appeal stage.
Doctrine:
The Court establishes that a condition precedent to an obligation is not necessarily potestative (dependent exclusively on the will of the debtor) when it is contingent upon other events beyond the debtor’s control, such as finding a willing buyer for property.
Class Notes:
– Potestative condition: A condition that depends solely on the will of a debtor makes an obligation null and void.
– Mixed condition: An obligation subject to conditions partly within the debtor’s control and partly dependent on external factors is valid and enforceable.
– Statute of limitations: A claim must be made within a specified time frame to be valid; however, the timeframe for a conditional obligation is measured from the occurrence of the condition.
– Statute of non-claims: Claims against an estate must be filed within the time and manner prescribed by law, or they may be barred.
Historical Background:
This case illustrates post-World War II era jurisprudence in the Philippines concerning obligations and conditions precedent under the old Civil Code, which reflects the fusion and evolution of Spanish civil law traditions within Philippine legal systems. The Court’s analysis of conditions for repayment linked to property sales abroad demonstrates how international factors can play a role in domestic legal disputes. The case reflects the period’s legal philosophy and interpretation of testamentary dispositions and conditions affecting estates.
Leave a Reply