Title
Martin vs. Boyero
Case
G.R. No. 33493
Decision Date
Mar 6, 1931
Plaintiff sued defendant over unpaid P20,000 from estate sale, alleging lease violated contract. Court ruled lease valid, debts unpaid, and condition not void; plaintiff’s claim dismissed.
sale price
terms of the contract
conditional obligation
A

Case Digest (G.R. No. 33493)

Facts:

  • Nature of the action and parties’ positions
  • Enrique Martin (plaintiff and appellant) brought an action based on rights he derived from Pedro Zorrilla, of whom he was successor-in-interest.
  • Martin alleged that the sale price for the undivided two-fifths (2/5) of the Espana Estate had become demandable because Francisco Boyero (defendant and appellee) allegedly violated the terms of the contract of sale.
  • Martin prayed for payment of the price amounting to P20,000, plus interest, costs, and other legal and equitable remedies, including the rendering of an account of the estate.
  • Boyero answered by denying the material allegations and raising special defenses that:
1) the action was premature and contrary to law; 2) he had not violated the contract of sale; and 3) the complaint was vague and ambiguous.
  • Accounting proceedings during the case in the Court of First Instance
  • On March 13, 1929, while the case was pending in the Court of First Instance, the court ordered Boyero to render an accounting.
  • The accounting required Boyero to disclose:
1) products of the Espana Estate received by him from December 21, 1925, when the sale took place; 2) the obligations then attached to the estate; 3) how those obligations were met; and 4) the loans obtained by Boyero upon the estate, including their application.
  • Boyero rendered the account; Martin raised objections; Boyero answered the objections.
  • On October 22, 1929, the trial court required Boyero to furnish certain data and a summary of the state of the accounts.
  • Boyero complied; Martin again filed objections.
  • The case was tried on January 17, 1930.
  • Trial court judgment
  • Judgment was entered on February 26, 1930, absolving Boyero.
  • The trial court absolved Boyero on the following grounds:
1) The conditional obligation stated in the contract (Exhibit A) was void because it depended upon a condition void under article 1115 of the Civil Code, since fulfillment depended upon the exclusive will of the debtor. 2) Even assuming validity of the condition, Boyero had not violated the terms of Exhibit A, and the lease (Exhibit B) did not infringe the conditions contained in Exhibit A. 3) Even assuming the condition were valid, it could not be complied with because the obligor had never voluntarily prevented its fulfillment; instead, he had endeavored to comply by reducing the debts of the Espana Estate within the narrow margin allowed by the price of sugar in the last few years. 4) Martin failed to show that the debts of the Espana Estate had been fully satisfied; thus, he had no present right to demand fulfillment of the conditional obligation, even assuming validity, and the grounds of action were not well taken.
  • Issues raised on appeal
  • Martin appealed from the February 26, 1930 judgment and assigned alleged errors, namely:
1) The trial court erred in holding that Martin was not entitled to demand fulfillment because he had not shown that all debts appertaining to the estate had been fully satisfied. 2) The trial court erred in holding that Exhibit A left Martin “a wide and open field” that permitted Martin to impose further obligations, thereby delaying fulfillment at will. 3) The trial court erred in holding that the contract of lease (Exhibit B) did not violate the conditions in Exhibit A. 4) The trial court erred in failing to hold that article 1119 of the Civil Code was not applicable to the case at bar. 5) The trial court erred in dismissing the complaint.
  • Key contractual stipulations in the deed of sale (Exhibit A)
  • The deed of sale conveyed to Martin’s predecessor-in-interest two-fifths (2/5) of the Espana Estate to be paid by Boyero through a conditional payment of P20,000.
  • Payment stipulations were as follows:
1) Boyero would pay P20,000 after he paid his debts to the Hogar Filipino and Messrs. Hijos de I. de la Rama, or to any other person/entity to whom Boyero was indebted for exploitation of the Espana Estate, whether such indebtedness was present or future. 2) Ten thousand pesos (P10,000) would be paid “upon the date when the aforesaid estate becomes free of all incumbrances.” 3) The remaining ten thousand pesos (P10,000) would be paid within the following year and would earn interest at ten percentum per annum, computed from the date when the estate became free of all encumbrances until fully paid. 4) If Boyero sold the estate voluntarily or under a judgment, and after payment of the debts encumbering the estate there remained a balance less than P50,000, Zorrilla (Martin’s predecessor-in-interest in rights) would receive only 2/5 of said balance, deducting sums Boyero had paid to Zorrilla from that date until the voluntary or involuntary sal...(Subscriber-Only)

Issues:

  • Validity and nature of the conditional obligation in Exhibit A
  • Whether the stipulation making payment of the P20,000 depend upon the satisfaction of debts encumbering the Espana Estate was void as a condition prohibited by article 1115 of the Civil Code because fulfillment depended exclusively on the will of the debtor.
  • Whether the contract left the time for payment entirely to Boyero’s discretion such that the conditional obligation was void for lack of a fixed term.
  • Applicability of Civil Code provisions invoked by the appellant
  • Whether article 1119 of the Civil Code applied such that the obligation became demandable upon the execution of the lease, given alleged prevention of fulfillment by Boyero.
  • Whether article 1117 of the Civil Code applied to the case so as to affect the effect of the condition’s fulfillment or non-fulfillment.
  • Whether article 1128 of the Civil Code applied as to the period for payment that the court was required to fix.
  • Whether Boyero violated Exhibit A through the lease (Exhibit B)
  • Whether the lease (Exhibit B) infringed the conditions stipulated in Exhibit A.
  • Whether Boyero’s acts in connection with leasing and associated financial arrangeme...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)
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