Name: April Ponce

Pineda vs. Zuñiga Vda. Devega

G.R. No. 233774, April 10, 2019
Topic: Article 1169
Facts:
This case is about De Vega borrowed P500,000 from Pineda, repayable in a year with an 8%
monthly interest. De Vega secured the loan with a real estate mortgage (2003 Agreement). Upon
maturity, De Vega failed to pay, leading Pineda to file a complaint. The RTC favored Pineda, but
the CA reversed, citing Pineda's lack of proof of prior demand. While agreeing with the lack of
evidence, the Supreme Court disagreed with the CA's legal conclusion, categorizing the
agreement as a Contract of Loan. It ruled that delay began when Pineda demanded payment
judicially, not requiring extrajudicial proof. Although there was no evidence of extrajudicial
demand, delay initiated with the filing of the complaint. Consequently, the Court affirmed the
CA's findings but disagreed with its legal conclusion. It classified the agreement as a Contract of
Loan, holding De Vega liable for damages and ordering the payment of P200,000.
Issue:
The main issue revolved around whether a demand letter was sent by Pineda and received by De
Vega.
Held/Ruling:
The Court affirmed the CA’s findings, stating that there was no proof of the demand letter being
sent and received.
The Court disagreed with the CA’s legal judgment while acknowledging the absence of evidence
supporting the prior demand. It claimed that the contract was a contract of loan, which caused a
delay when Pineda filed a lawsuit to demand payment. The Court held that the filing of the
complaint marked the beginning of the delay, even in the absence of evidence of an extrajudicial
demand. De Vega was therefore deemed to be in default and held accountable for damages,
upholding the RTC’s decree that P200,000 be paid.