Facts:

The case of Casiana Bismorte vs. Aldecoa & Co. (G.R. No. 5586) was decided on December 10, 1910. The plaintiff, Casiana Bismorte, a married woman, initiated legal proceedings to reclaim possession of a steamboat, the San Rafael, which she claimed was her exclusive property. The action was brought without her husband, Manuel Veloso, being joined as a party. The defendant, Aldecoa & Co., raised a special defense asserting that Bismorte lacked the legal capacity to sue independently due to her marital status, citing Section 115 of the Code of Civil Procedure. The lower court ruled in favor of Aldecoa & Co., dismissing Bismorte's complaint on the grounds of her lack of capacity to sue without her husband. Following this, Bismorte appealed the decision. During the appeal, the court permitted her to amend her complaint to focus solely on the recovery of the steamboat, excluding claims for damages related to its detention. The case involved a public notarial docume...

Facts:

1. Parties Involved:

   • Plaintiff and Appellant: Casiana Bismorte, a married woman.
   • Defendant and Appellee: Aldecoa & Co.

2. Nature of the Case:

   • The plaintiff, Casiana Bismorte, filed a lawsuit in her own name (without joining her husband) to recover possession of a steamboat, the San Rafael, which she claimed was her exclusive property. She also sought damages for the alleged wrongful detention of the steamboat.

3. Legal Capacity Issue:

   • The defendant raised the defense that the plaintiff, being a married woman, lacked the legal capacity to sue without joining her husband, citing Section 115 of the Code of Civil Procedure.

4. Amended Complaint:

   • During the appeal, the court allowed the plaintiff to amend her complaint by removing the claim for damages, leaving only the recovery of the steamboat as the subject of the action.

5. Husband’s Interest:

   • The plaintiff’s husband, Manuel Veloso, had an interest in the income generated by the steamboat, which was considered paraphernal property (property owned by the wife).

6. Contractual Background:

   • A notarial document (Exhibit A) dated July 2, 1907, revealed that Manuel Veloso, acting on behalf of himself and his wife, Casiana Bismorte, entered into an agreement with Aldecoa & Co. to settle his debts.
   • Veloso sold parcels of real estate to Aldecoa & Co. with the right to repurchase, and the steamboat San Rafael was excluded from the sale, with the agreement stating that it would become the exclusive property of Casiana Bismorte.
   • The contract required Casiana Bismorte to ratify the agreement within two months, but there was no evidence that she did so formally. However, her filing of the lawsuit was deemed sufficient ratification.

7. Defendant’s Argument:

   • Aldecoa & Co. argued that the plaintiff failed to prove that the property she transferred to them was acquired with her separate funds or that it belonged to her exclusively.

8. Estoppel by Contract:

   • The court found that Aldecoa & Co. was estopped from denying the plaintiff’s ownership of the lands transferred, as they had accepted the lands as her property in the contract.

Issue:

1. Legal Capacity to Sue:

   • Whether the plaintiff, a married woman, could bring the action in her own name without joining her husband.

2. Ownership of the Steamboat:

   • Whether the steamboat San Rafael was the exclusive property of the plaintiff, Casiana Bismorte, as stipulated in the contract.

3. Estoppel:

   • Whether Aldecoa & Co. was estopped from denying the plaintiff’s ownership of the steamboat, given the terms of the contract.

4. Ratification of the Contract:

   • Whether the plaintiff’s filing of the lawsuit constituted sufficient ratification of the contract, even in the absence of a formal notarial instrument.

Ruling:

The Supreme Court reversed the lower court’s decision and ruled in favor of the plaintiff, Casiana Bismorte. The court held that:

1. Legal Capacity:

   • The plaintiff had the legal capacity to sue for the recovery of the steamboat, as the contract specifically designated the steamboat as her exclusive property.

2. Ownership of the Steamboat:

   • The steamboat San Rafael was the exclusive property of the plaintiff, as stipulated in the contract (Exhibit A). The defendant was estopped from denying her ownership.

3. Estoppel by Contract:

   • Aldecoa & Co. was estopped from raising the issue of the plaintiff’s ownership, as they had accepted the lands as her property and agreed that the steamboat would be her exclusive property.

4. Ratification:

   • The plaintiff’s filing of the lawsuit was deemed sufficient ratification of the contract, even in the absence of a formal notarial instrument.

The case was remanded to the lower court for further proceedings.

Ratio:

1. Estoppel by Contract:

   • A party to a contract cannot deny the facts or terms explicitly agreed upon in the contract. Aldecoa & Co. was estopped from denying the plaintiff’s ownership of the steamboat because they had accepted the lands as her property and agreed that the steamboat would be her exclusive property.

2. Ratification by Conduct:

   • Ratification of a contract can be implied through conduct. The plaintiff’s filing of the lawsuit was sufficient to ratify the contract, even without a formal notarial instrument.

3. Separate Obligations:

   • The obligations of the plaintiff and her husband under the contract were distinct. The plaintiff fulfilled her obligations, and the defendant could not hold her responsible for her husband’s failure to comply with his part of the agreement.

4. Public Policy and Fair Dealing:

   • The principle of estoppel promotes fair dealing and prevents parties from taking inconsistent positions to the detriment of others. The defendant’s attempt to deny the plaintiff’s ownership after benefiting from the contract was contrary to principles of justice and equity.

5. Exclusive Ownership of Paraphernal Property:

   • Under Article 1396 of the Civil Code, the steamboat became the plaintiff’s paraphernal (exclusive) property, as it was acquired in exchange for her lands, which were her separate property.