Ildefonso Doronila v. Graciano Gonzaga

Summary

This case involved a debt collection action where former guardian Ildefonso Doronila sued Graciano Gonzaga for P3,208.50 plus interest. Doronila had previously served as tutor to minor heirs of Pablo Ledesma and, after extensive litigation, made a settlement agreement with the heirs through the family council, acquiring ownership of uncollected estate accounts. The Supreme Court affirmed Doronila's legal capacity to sue and the principal debt amount, but modified the interest award. The Court held that under Civil Code provisions, interest on obligations without contractual interest provisions can only be collected from the time of judicial or extrajudicial demand. Since no demand was made until the filing of the lawsuit in May 1905, interest should only run from that date rather than from 1897 as the lower court had ruled. The case establishes important precedent on when interest begins to accrue on unpaid obligations under Philippine civil law.