Radio Corporation of the Philippines v. Jesus R. Roa

Summary

This case involves a surety dispute where Radio Corporation of the Philippines sued Jesus R. Roa for unpaid installments on a P28,400 debt, along with his sureties Ramon Chavez, Andres Roa and Manuel Roa. The key issue was whether extending payment time to the principal debtor without the sureties' consent discharged them from liability. The contract contained an acceleration clause making the full balance due upon any default. When Roa defaulted on his February 1932 payment, Radio Corporation granted an extension until April 1932 without informing the sureties. The Supreme Court reversed the trial court's judgment against the sureties, applying Article 1851 of the Civil Code which provides that extension granted to a debtor without guarantor consent extinguishes the guarantor's liability. The Court found that since the acceleration clause made the entire debt due upon default, extending one installment effectively extended the whole obligation, thereby discharging the sureties completely. This decision reinforces the strict protection afforded to sureties under Philippine law.