GUINTO V. MEDINA, 50 O.G. #1 P. 199, October 7, 1953.

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GUINTO V. MEDINA, 50 O.G. #1 p. 199, October 7, 1953.

DOCTRINE:
- SC held that the heirs of a defendant in a civil action is liable for damages for such action survives despite the
defendant’s death.
- As they are merely substituted in place of Santiago Medina upon his death, their liability is only up to the
extent of the value of the property, which they might have received from the original defendant, Santiago
Medina.

FACTS:
Leon Guinto filed an action for forcible entry against Santiago Medina alleging that he has been in possession of
the said parcel of land since 1934 and that Medina by means of force and intimidation deprived him of his
possession thereof. The trial court ruled in favor of Guinto but it dismissed the prayer for damages. Pending
appeal, Medina died. Medina was substituted by his heirs. The Court awarded the damages appealed.

ISSUE:
Whether or not the heirs of Medina are liable for damages, and if in the affirmative to what extent.

RULING:
YES. The action to recover damages survives notwithstanding the death of the adverse party whom damages are
sought to be recovered. In this case, the heirs of Medina are liable to pay the damages as they are merely
substituted in the place of Medina upon his death. However, their liability is only to the extent of the value of the
property, which they might have received from the deceased defendant.

Facts: on October 3, 1941 Leon Guinto filed an action for forcible entry against Santiago Medina. Guinto alleged that he has been in
possession of the said land since 1934, and that on 1941 by means of force and intimidation. Medina deprived him of his possession. Trial
Court rendered decision in favor of Guinto. While the case was on its original appeal Santiago died.

Issue: whether the liability of heirs may exceed the amount of inheritance?

Held: no, the heirs of the original defendants in this case has been merely substituted in his place upon his death, their liability for damages
(money debt) is only to the extent of the value of the property that they might have received if any from him.

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