People v. Chaves G.R. No. L-19521.

October 30, 1964

Facts:

Esteban Chaves has been found guilty by the CFI and CA of a violation of RA 145. He collected a claim for
Marcela Rambuyon for death benefits in the sum of $4,252 due for the demise of her son, a USAFFE
veteran. The check was cashed by Chaves and gave only P3, 202.20 to the claimant and retained P5,
362.20 for himself. He was sentenced to indemnify the offended party the sum of P5, 362.20 and costs.
However, the indemnity has not been paid yet. So the sheriff resorted into taking a residential lot and
building of the accused. The accused claimed that it was a recorded family home extra-judicially.

Issue: Whether or not, the family home extrajudicially constituted is entitled to exemption from the
execution levy issued at the instance of the offended party.

Held: No.

Ratio: Article 243, paragraph 2 of the Civil Code provides that debts incurred before the declaration was
recorded in Registry of Property shall be exempted. However, the Supreme Court ruled that it is of no
merit that the appellant considered his unpaid indemnity due as a debt, and that, the word “debt: shall
be treated in its generic sense.

StatCon maxim: The context may circumscribe the meaning of a statute; it may give a word or phrase a
meaning different from its usual or ordinary signification. In such a case, the meaning dictated by the
context prevails.