Jennefer Figuera v. Maria · G.R. 204264

Petitioner: Jennefer Figuera
Respondent: Maria Remedios Ang
Citation: G.R. No. 204264
Court: Supreme Court
Division: Second Division
Ponente: Brion, J.
Decided: June 29, 2016

Summary

This case involves a dispute over payment under a business assignment agreement. Figuera purchased Ang's business for P150,000.00, with Ang obligated to pay December 2004 utility bills. When Figuera paid these bills (P107,903.21) without Ang's consent and tendered only the balance (P42,096.79), Ang refused payment demanding the full amount. The RTC and CA ruled for Ang, finding no authority for Figuera to deduct payments. However, the Supreme Court reversed, applying Civil Code provisions on legal subrogation and compensation. It held that as the interested new business owner, Figuera's payment subrogated her to the creditors' rights against Ang without need for consent, and legal compensation extinguished both parties' obligations by operation of law. The Court validated Figuera's tender of the remaining balance and her subsequent consignation when Ang unjustifiably refused payment.

Statutes applied

Related cases

Other Philippine cases on the same provisions and issues.

Joseph N. Wolfson v. The Estate of Francisco Martinez G.R. No. 5970
Agustin Ga. Gavieres v. The Administrators of the Estate of Luis Pena G.R. No. 4992
Cecilleville Realty v. Spouses Tito Acuña G.R. No. 162074
Rosemarie Q. Rey v. Cesar G. Anson G.R. No. 211206
Jose Vaca v. Manuel Kosca G.R. No. 8394

By Intellegal Editorial Board · June 29, 2016

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