Marco Antonio Chagoya & Jose Manuel Figueroa v. Mario Vilchis

CourtCourt of Appeals of Texas
DecidedJuly 16, 2024
Docket01-22-00864-CV
StatusPublished

This text of Marco Antonio Chagoya & Jose Manuel Figueroa v. Mario Vilchis (Marco Antonio Chagoya & Jose Manuel Figueroa v. Mario Vilchis) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marco Antonio Chagoya & Jose Manuel Figueroa v. Mario Vilchis, (Tex. Ct. App. 2024).

Opinion

Opinion issued July 16, 2024

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-22–00864-CV ——————————— MARCO ANTONIO CHAGOYA AND JOSE MANUEL FIGUEROA, Appellants V. MARIO VILCHIS, Appellee

On Appeal from the 215th District Court Harris County, Texas Trial Court Case No. 2021-42426

MEMORANDUM OPINION ON REHEARING

Appellants Marco Antonio Chagoya and Jose Manuel Figueroa moved for

rehearing of our April 27, 2023 opinion and judgment dismissing this appeal for

want of prosecution. In a June 20, 2023 order, we granted the motion for rehearing, withdrew our April 27, 2023 opinion and judgment, and reinstated the appeal. We

now issue this opinion and judgment on the merits of the appeal.

Chagoya and Figueroa sued appellee Mario Vilchis for allegedly breaching

separate oral agreements. Chagoya and Figueroa asserted a single cause of action for

breach of contract, and Figueroa asserted an alternative claim for quantum meruit.

Vilchis filed a traditional and no-evidence motion for summary judgment on all the

claims. The trial court granted the motion and dismissed Chagoya’s and Figueroa’s

claims.

In a single issue with several subparts on appeal, Chagoya and Figueroa

contend that the trial court erred by granting the motion for summary judgment

because genuine issues of material fact exist concerning: (1) Chagoya’s breach of

contract claim; (2) Figueroa’s breach of contract claim and alternative quantum

meruit claim; (3) whether the statute of limitations bars Chagoya’s breach of contract

claim; and (4) whether the statute of frauds bars Chagoya’s claims. Chagoya and

Figueroa further contend that (5) Vilchis did not establish that he was entitled to

judgment as a matter of law based on Chagoya’s and Figueroa’s joinder of unrelated

claims in one lawsuit. We affirm in part and reverse and remand in part.

2 Background

Chagoya and Figueroa alleged that they separately entered into oral

agreements with Vilchis which Vilchis breached. Except for the alleged contractual

relationships, there is no apparent relationship between the parties.

Chagoya alleged that he entered into two separate oral agreements with

Vilchis. First, on October 4, 2018, he allegedly loaned $10,000 to Vilchis to be

repaid in one year pursuant to an oral agreement. Second, in March 2019, Chagoya

allegedly paid Vilchis $700 and loaned him an additional $3,000 in exchange for

Vilchis performing paint and body work on Chagoya’s vehicle. Vilchis did not

perform the work on the vehicle or return it to Chagoya, and Vilchis repaid only

$8,000 on the $13,000 principal of both loans. Chagoya further alleged that Vilchis

filed a criminal charge against him to avoid repaying the debt, requiring Chagoya to

hire counsel and incur attorney’s fees defending against the criminal charge. As a

result of these transactions, he alleged that Vilchis owed him $14,700: $5,000 for

the unpaid balance remaining on the two loans; $5,000 for the value of Chagoya’s

vehicle that Vilchis never returned; $700 for the payment Chagoya made for vehicle

work that was not performed; and $4,000 in legal fees incurred by Chagoya in

defending against the criminal charge.

Figueroa alleged that he and Vilchis entered into one oral agreement in

November 2018. Figueroa agreed to perform remodeling services for Vilchis in

3 exchange for a truck valued at $5,000. Figueroa performed the remodeling services,

but Vilchis did not deliver the truck.

In July 2021, Chagoya and Figueroa filed suit against Vilchis. Vilchis filed

special exceptions, verified denials, and an answer. In January 2022, Chagoya and

Figueroa filed their live pleading, a first amended petition asserting a single cause

of action for breach of contract. Figueroa also asserted an alternative cause of action

for quantum meruit. They sought actual damages, interest, costs, and attorney’s fees.

Vilchis filed a traditional and no-evidence motion for summary judgment. He

asserted four traditional grounds. First, he argued that Chagoya’s and Figueroa’s

“claims were procedurally defective because they improperly joined unrelated

claims” in one lawsuit. Vilchis argued that the trial court had previously granted his

special exceptions and required Chagoya and Figueroa to replead to cure the defect,

but they did not replead. Vilchis requested that the trial court strike Chagoya’s and

Figueroa’s pleadings or alternatively grant summary judgment and dismiss the

Second, Vilchis argued that the four-year statute of limitations barred

Chagoya’s claim for breach of contract concerning the alleged $10,000 loan. Vilchis

denied that he made an oral agreement with Chagoya at all, including in October

2018. Rather, Vilchis contended that Chagoya had loaned $10,000 to Vilchis’s

father, Felix Vilchis Castro, in October 2013, and Chagoya sought to recover

4 Castro’s debt from Vilchis. Vilchis argued that this claim was barred by the statute

of limitations. He further argued that his mother had repaid Chagoya for Castro’s

debt. He supported this argument with an affidavit in which he stated the details of

an alleged October 2013 loan agreement between Chagoya and Castro, although

Vilchis conceded that he “was not a witness to the agreement[.]” Vilchis also

produced a bank withdrawal slip purporting to show a $10,000 withdrawal. Vilchis

averred that he was the custodian of his mother’s financial records, and the bank slip

reflected that $10,000 was withdrawn from his mother’s account. This amount was

then used to repay Chagoya for the October 2013 loan to Castro.

Third, Vilchis argued that the statute of frauds barred Chagoya’s claims.

Relying on the alleged 2013 loan agreement between Chagoya and Castro, Vilchis

characterized this claim as one seeking to recover for the debt of a third party. Vilchis

argued that the statute of frauds requires that, to be enforceable, a promise by one

person to pay for the debt of another person must be in writing and signed by the

promisor. Because there was no evidence of a signed writing, Vilchis argued that

Chagoya’s claims were barred by the statute of frauds.

Fourth, Vilchis argued that no legal authority authorized Chagoya to recover

legal fees incurred in defending against a criminal charge in a separate proceeding.

Finally, Vilchis raised no-evidence challenges to Chagoya’s and Figueroa’s

claims. Vilchis argued that Chagoya and Figueroa had no evidence to support

5 multiple elements of their breach of contract claim and Figueroa’s alternative claim

for quantum meruit.

Chagoya and Figueroa filed a joint summary judgment response. They did not

directly address any of Vilchis’s traditional summary judgment grounds, although

Chagoya disputed that he was suing Vilchis based on an agreement between

Chagoya and Vilchis’s father. Chagoya and Figueroa produced unsworn declarations

describing the various oral agreements they each entered into with Vilchis, and they

relied on these declarations as their primary summary judgment evidence.

Vilchis filed a reply. He objected to Chagoya’s and Figueroa’s declarations

and sought to strike them. Vilchis argued that the declarations were conclusory, self-

serving, hearsay, and lacked corroborating evidence. Vilchis similarly attacked the

declarations when arguing that Chagoya and Figueroa produced no evidence to

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