Case Digest: Liguez vs. Court of Appeals, et. al., G.R. No. L-11240

Liguez vs. Court of Appeals, et. al., G.R. No. L-11240, December 18, 1957

Subject: Obligations and Contracts

FACTS

Liguez filed a lawsuit against the late Salvador P. Lopez's widow and children to get back 51.84 hectares of land. Plaintiff said that she was the legal owner of the land because the late owner, Salvador P. Lopez, had given it to her in a deed of gift. The defense said that the donation was invalid because the plaintiff had sexual relations with Salvador P. Lopez, who was already married, and that Lopez's property had been given to the appellees as his heirs. The Court of Appeals ruled that the deed of donation was not valid because (1) Lopez had no right to give his wife's property to the plaintiff appellant and (2) the donation was tainted with illegal causa or consideration (an illegal sexual relationship) in which both the donor and the donee took part.

The appellant argues strongly that both the Court of First Instance and the Court of Appeals made a mistake when they ruled that the donation was null and void because it was made for an illegal cause or reason. People say that Article 1274 of the Civil Code of 1889, which was in effect in 1943 when the donation was made, says that "in contracts of pure beneficence the consideration is the liberality of the donor" and that generosity in and of itself can never be illegal because it is neither against the law nor against morals nor against public policy.

ISSUE

Whether or not the donation be considered valid.

RULING

No.  

Under the law (Art 1352, NCC), contracts without cause, or with unlawful cause, produce no effect whatsoever. The cause is unlawful if it is contrary to law, morals, good customs, public order or public policy.

In this case, it is clear that the late Salvador P. Lopez wasn't just trying to help the appellant Conchita Liguez. He also wanted her to live with him so he could satisfy his sexual desires. Lopez told the witnesses Rodriguez and Ragay that he loved the appellant, but her parents wouldn't let him marry her unless he gave her the land in question. So, in reality, the donation was just one part of a complicated deal (at least with the appellant's parents) that needs to be looked at as a whole. Taking all of this into account, it is clear that the conveyance was based on an illegal cause.