Venancio Queblar v. Leonardo Garduño

Summary

This case involves a loan dispute where Judge Leonardo Garduño borrowed money from the Basa spouses to purchase Manila real estate, with their rights later assigned to plaintiff Venancio Queblar. The central issue was whether the true loan amount was P2,100 (as claimed by Garduño) or P8,400 (as stated in the deed). Garduño argued the extra P6,300 represented the lenders' agreed share of expected profits from resale. The Supreme Court rejected this defense, finding P8,400 was the actual amount loaned. The Court applied Article 1100 of the Civil Code, ruling that without an express default clause, interest only accrues from judicial demand (complaint filing). The decision established that loan contracts requiring full payment upon missed installments don't automatically create default without express stipulation, and awarded reasonable attorney's fees at 5% of the debt.