Petitioner
Oriental Commercial Co.
Respondent
Quirico Abeto
Citation
G.R. No. 42391
Court
Supreme Court En Banc
Division
En Banc
Ponente
Imperial, J.
Decided
October 10, 1934

Summary

Oriental Commercial Co. sought execution of a Supreme Court judgment against three defendants for P5,742.73 plus attorney's fees. When Alejo Mabanag claimed he was only jointly liable and entitled to benefit of exhaustion as surety, the trial court suspended execution against him. The Supreme Court, through certiorari, clarified that under Civil Code Articles 1137-1138, defendants in a judgment are only jointly liable (not jointly and severally) unless expressly stated otherwise, meaning each pays only their proportionate share. However, the Court rejected Mabanag's claim for benefit of exhaustion, ruling that the final judgment did not recognize any defendant as surety. This case established important precedent on interpretation of joint versus solidary obligations in Philippine civil law.

Statutes applied

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By the Intellegal Editorial Board · October 10, 1934

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