Provincia Del Santisimo Nombre De Jesus v. Del Rey
REITERATIONFacts
The Antecedents: The plaintiff corporation, Provincia del Santisimo Nombre de Jesus de Filipinas, prayed for judgment against the defendants, Leon del Rey and others, to jointly and severally pay P41,670.87 with 9% annual interest from June 15, 1928, plus legal interest from the filing of the complaint, and P4,807.90 with legal interest from the institution of the action. The plaintiff further sought the foreclosure and sale at public auction of a P75,000 mortgage credit held by defendant Jose Marin against Felipa P. Alberto if the defendants failed to pay within three months from judgment. Procedural History: The defendants Leon del Rey and Jose Marin contended that the document (Exhibit C) was null and void due to coercion, threat, and intimidation, and that the plaintiff owed them P6,997.89. After trial, the Court of First Instance rendered judgment holding Del Rey and Marin jointly and severally liable for P41,670.87 with 9% interest from June 15, 1928, and P4,807.90 with 6% interest from January 12, 1929. They were ordered to deposit these sums within three months, or face foreclosure of the mortgage credit. The plaintiff was absolved from the defendants' counterclaim. The Petition: The defendants appealed, assigning errors including the trial court's failure to declare the document null and void due to coercion, threat, and intimidation; errors in the accountant's report; rejection of their claim for expenses; denial of a new trial; and rendering judgment for the plaintiff instead of absolving the defendants.
Issue(s)
Whether the document (Exhibit C) executed on June 15, 1928, is null and void for having been obtained through coercion, threat, and intimidation practiced on Leon del Rey. Whether the accountant Francisco Santiago's report (Exhibit 4) contained errors such that Leon del Rey was charged with sums he was not bound to pay. Whether the defendants' claim for Leon del Rey's expenses for repairing and painting the facade of the Church of St. Augustine should be rejected. Whether the trial court erred in denying the defendants' motion for a new trial. Whether the trial court erred in rendering judgment for the plaintiff corporation instead of absolving the defendants.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance, holding the defendants Leon del Rey and Jose Marin jointly and severally liable for the sums awarded, with costs against the appellants. The plaintiff corporation was absolved from the defendants' counterclaim.
Ratio Decidendi
On the issue of coercion, threat, and intimidation: The Court held that there was no evidence of coercion, threat, or intimidation practiced upon Leon del Rey to compel him to sign the mortgage deed. The alleged estafa charge, Father Mariano Rodrigo's remarks, and Father Castrillo's recommendation did not constitute coercion, threat, or intimidation that would vitiate consent. The Court reiterated the principle that it is necessary to distinguish between real duress and the motive present when one gives consent reluctantly, citing Martinez vs. Hongkong & Shanghai Banking Corporation. A contract remains valid even if a party enters into it against their wishes or better judgment, as long as there is no vitiating force. Furthermore, the evidence showed a series of offers leading up to the contract, and the defendants acted in accordance with it after execution, confirming its validity. On the alleged errors in the accountant's report: The Court found that the defendants had discussed and reviewed the accountant's report (Exhibit 4) prior to the contract's execution. The defendants were not entitled to a review of their accounts with the plaintiff's predecessor, as these were liquidated with their consent, as evidenced by the contract itself. They could not deny their own acts, citing Asis vs. Pardo, Aldecoa & Co. vs. Warner, Barnes & Co., and Gutierrez Hermanos vs. Oria Hermanos & Co. On the claim for expenses for repairing and painting the church facade: The Court ruled that these expenses were neither alleged nor claimed in due time in the first instance, and there was no apparent obligation for the plaintiff to pay for them. Therefore, the rejection of this claim was proper. On the denial of the motion for a new trial: The Court found that the preceding assignments of error, which were found to be without merit, were the basis for the motion for a new trial. Since the preceding assignments of error lacked merit, the denial of the motion for a new trial was also proper. On the rendition of judgment for the plaintiff: As all preceding assignments of error were found to be without merit, the trial court's judgment in favor of the plaintiff corporation was sustained. The appeal was deemed to have no merit, leading to the affirmation of the appealed judgment.
Main Doctrine
A contract is valid even though one of the parties entered into it against his wishes and desires or even against his better judgment, provided there is no real duress, threat, or intimidation vitiating consent. A contract cannot be annulled on the ground of coercion, threat, or intimidation if the evidence does not support such claims and if the parties acted in accordance with the contract after its execution, thereby confirming it.