- Petitioner
- Felipe Agoncillo
- Respondent
- Crisanto Javier
- Citation
- G.R. No. 12611
- Court
- Supreme Court En Banc
- Division
- En Banc
- Ponente
- Fisher, J.
- Decided
- August 7, 1918
Summary
This landmark 1918 Supreme Court case established important principles regarding joint obligations and prescription under the Civil Code. The Agoncillos sued to collect a debt from 1904 where the Alano brothers promised to pay P2,730.50 with alternative property conveyance upon default. The Court held that claims against deceased Anastasio Alano's estate were barred for failure to present to the statutory claims committee. Regarding the surviving joint debtors, the Court ruled that joint obligations create separate debts under Civil Code Article 1138, so the 1908 payment by one debtor (Anastasio) could not interrupt the prescription period for the others (Jose and Florencio). The 10-year prescription period had expired when the complaint was filed in 1916. The decision emphasized that joint debtors are liable only for their proportionate shares unless solidarity is expressly stipulated, and acts by one joint debtor do not benefit or prejudice the others regarding prescription.