Case Digest (G.R. No. L-13403) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Ramon E. Saura vs. Estela P. Sindico, G.R. No. L-13403, decided on March 23, 1960, appellant Ramon E. Saura and appellee Estela P. Sindico both sought the Nacionalista Party’s nomination for Congress in Pangasinan’s Fourth District for the November 12, 1957 election. On August 23, 1957, they executed a written agreement pledging that “Each aspirant shall respect the result of the aforesaid convention, i.e., no one of us shall either run as a rebel or independent candidate after losing in said convention.” At the provincial convention on August 31, 1957, Saura was proclaimed the official candidate. Despite the covenant, Sindico submitted her certificate of candidacy on September 6, 1957, and actively campaigned. Saura filed suit for damages on October 5, 1957, in the Court of First Instance of Pangasinan. By order of November 19, 1957, the trial court dismissed the complaint, ruling the agreement void because it involved a public office beyond Case Digest (G.R. No. L-13403) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Political Context
- Ramon E. Saura (plaintiff-appellant) and Estela P. Sindico (defendant-appellee) were aspirants for the Nacionalista Party nomination in Pangasinan’s Fourth District for the November 12, 1957 congressional elections.
- Both parties sought to become the official Nacionalista candidate through a provincial convention.
- Written Agreement of August 23, 1957
- The aspirants executed a covenant pledging that “Each aspirant shall respect the result of the aforesaid convention, i.e., no one of us shall either run as a rebel or independent candidate after losing in said convention.”
- The agreement contemplated mutual restraint from post-convention independent or rebel candidacies.
- Party Convention and Alleged Breach
- On August 31, 1957, the Nacionalista Party provincial convention proclaimed Saura as its official candidate.
- Sindico filed her certificate of candidacy on September 6, 1957 and conducted an active independent campaign, contrary to the covenant.
- Judicial Proceedings
- On October 5, 1957, Saura filed suit for damages against Sindico for breach of the August 23 agreement.
- The Court of First Instance of Pangasinan, by order of November 19, 1957, dismissed the complaint, holding the contract void as to subject matter (public office) and repugnant to public policy (curtailment of the elective franchise).
Issues:
- Whether the August 23, 1957 agreement regarding non-contest of candidacy after losing is a valid and enforceable contract.
- Whether the pledge impermissibly curtails the free exercise of the elective franchise and is thus against public policy.
- Whether plaintiff is entitled to damages for alleged breach of the said agreement.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)