Angel Gonzalez v. Jeremias J. Harty

Summary

Angel Gonzalez, chaplain of a foundation established by Petronila de Guzman, sued ecclesiastical administrators for additional revenues after having received settlements for years 1901-1910 and signing receipts acknowledging full satisfaction. The Court of First Instance awarded him P19,090.28, but the Supreme Court reversed, establishing the important principle that approved accounts cannot be revised absent proof of fraud, error, or mistake. The Court applied Civil Code provisions on consent and error in contracts, holding that Gonzalez's signed receipts over multiple years, particularly his 1910 receipt stating the payment was in 'full satisfaction' of all revenues due, constituted binding approval and waiver of further claims. This case clarifies the finality of approved settlements and the high burden required to reopen completed accounts.