- Petitioner
- Urbano Floriano
- Respondent
- Esteban Delgado
- Citation
- G.R. No. 4410
- Court
- Supreme Court En Banc
- Division
- En Banc
- Ponente
- Torres, J.
- Decided
- August 27, 1908
Summary
This 1908 Supreme Court case involved debt collection where Urbano Floriano sued married couple Esteban Delgado and Regina Bertumen for P1,352.80 under a promissory note with 10% annual interest. The defendants failed to answer the complaint, resulting in default judgment. The Supreme Court affirmed, ruling that under Civil Code Article 1113, obligations without specified payment terms are immediately demandable. The Court rejected arguments for extension of time, finding no indication the creditor intended to grant additional time for payment. The decision established that promissory notes without payment dates create immediately enforceable obligations, and that married couples are jointly liable for debts they both execute. The case demonstrates early application of Civil Code provisions on obligations and contracts in the American colonial period.