Tuesday, July 11, 2023

Case Digest: Mercedes Canullas vs Hon. Willelmo Fortun, G.R. No. 57499

Mercedes Canullas vs Hon. Willelmo Fortun, GR No. 57499, June 22, 1984

Subject: Obligations and Contracts

FACTS

Petitioner MERCEDES Calimlim-Canullas and FERNANDO Canullas were married on December 19, 1962. They begot five children. They lived in a small house on the residential land in question with an area of approximately 891 square meters, located at Bacabac, Bugallon, Pangasinan. After FERNANDO's father died in 1965, FERNANDO inherited the land.

In 1978, FERNANDO abandoned his family and was living with private respondent Corazon DAGUINES. During the pendency of this appeal, they were convicted of concubinage in a judgment rendered on October 27, 1981 by the then Court of First Instance of Pangasinan, Branch II, which judgment has become final.

On April 15, 1980, FERNANDO sold the subject property with the house thereon to DAGUINES for the sum of P2,000.00. In the document of sale, FERNANDO described the house as "also inherited by me from my deceased parents."

Unable to take possession of the lot and house, DAGUINES initiated a complaint on June 19, 1980 for quieting of title and damages against MERCEDES. The latter resisted and claimed that the house in dispute where she and her children were residing, including the coconut trees on the land, were built and planted with conjugal funds and through her industry; that the sale of the land together with the house and improvements to DAGUINES was null and void because they are conjugal properties and she had not given her consent to the sale.

ISSUE

Whether or not the contract of sale was valid under the circumstances surrounding the transaction.

RULING

No.

Under the law (Art 1409, NCC) (1), those contracts whose cause, object or purpose is contrary to law, morals, good customs, public order, or public policy are inexistent and void from the beginning. These contracts cannot be ratified. Neither can the right to set up the defense of illegality be waived.

In this case, the contract of sale was null and void for being contrary to morals and public policy. The sale was made by a husband in favor of a concubine after he had abandoned his family and left the conjugal home where his wife and children lived and from whence, they derived their support. That sale was subversive of the stability of the family, a basic social institution which public policy cherishes and protects.

No comments:

Post a Comment

Case Digest: General Santos Coca-Cola Plant Free Workers Union – TUPAS vs Coca-Cola Bottlers Philippines., Inc., CA and NLRC, G.R. No. 178647

  General Santos Coca-Cola Plant Free Workers Union – TUPAS vs Coca-Cola Bottlers Philippines., Inc., CA and NLRC,  G.R. No. 178647,  Februa...