OBLICON CASES BATCH 2 prepared by your friend, Matt, who did a full-text digest and hoping that you

continue to digest the rest of the cases under the topics, Consent & Acceptance, Void Contracts and
Voidable Contracts for the upcoming long quiz.

CONTRACTS

Perez vs Pomar 2 Phil 682

Facts: On August 27, 1902, Don Vicente Perez filed a complaint in the Court of First Instance of Laguna,
which he amended on January 17, seeking payment for interpreting services rendered to the Tabacalera
Company. He also requested $3,200 in damages. Perez alleged that Don Eugenio Pomar, the company's
agent, requested his interpreting services from December 8, 1901, to May 31, 1902, during which time
he abandoned his soap factory business. Perez claimed that Pomar had promised compensation.

Pomar denied these allegations, claiming that Perez accompanied him out of friendship and without any
formal request or promise of payment. He acknowledged lending Perez money and materials but
refuted any formal employment or significant profits resulting from Perez's services

Issue: WON an implied contract existed between Don Vicente Perez and Don Eugenio Pomar (acting on
behalf of the Tabacalera Company) for the interpreter services Perez rendered

Ruling: The court found that Perez had rendered interpreting services to Pomar and concluded that there
was an implicit contract, necessitating compensation. The court ruled that Pomar must pay Perez 200
Mexican pesos, deducting 50 pesos owed by Perez to Pomar. The judgment of the lower court was
affirmed and adjusted to reflect this decision.

Uy Tam vs Leonard 30 Phil 471

Facts: The dispute involves plaintiffs Uy Tam and Uy Yet, who supplied materials to a contractor, Hosty
and Brown, for a project involving the supply of crushed rock to the city of Manila. A bond was executed
by Hosty and Brown (as principals) and others, including George C. Sellner and Thomas Leonard (as
sureties), with the city of Manila named as obligee, to secure the performance of the contract. The
plaintiffs furnished the materials under the notification to the defendants that they accepted the
conditions of the bond relating to laborers and materialmen. However, when the city of Manila refused
to join the plaintiffs in enforcing the bond to recover costs, plaintiffs initiated legal action against the
defendants and the city as a pro forma party.

This case reached the Supreme Court through an appeal from a judgment of the Court of First Instance
of Manila, which sustained the defendants’ demurrer, asserting the complaint did not state facts
sufficient for a cause of action, leading to its dismissal with costs.

Issue: WON a third party not part of a bond agreement can enforce the bond based on stipulations
within that bond favoring such a third party.
Ruling: The Supreme Court ruled against the appellants, affirming the lower court’s decision on the
grounds that the bond did not stipulate a clear intention to benefit third parties (stipulations pour atrui).
The Court detailed that for a third party to claim a benefit under a contract, the intent of the contracting
parties to extend such a benefit must be expressly indicated. Moreover, the bond, in its clauses, did not
demonstrate an intention to directly confer benefit or enforceable right upon materialmen but was
crafted to secure the city of Manila against possible damages arising from the contract’s performance,
not to establish direct obligations to third parties.

Uy vs People G.R No. 174899 Sept. 11, 2008

Facts: Eugene Yu and Ramon L. Uy met in 1993 at a CREBA, INC. convention in Bacolod City and began a
business relationship in 1995 with a project in Parañaque City, where Uy was the developer and Yu the
exclusive marketer. Uy proposed a low-cost housing project in Cagayan de Oro, leading to an investment
agreement where Yu invested PHP 3,500,000 in exchange for PHP 4,500,000 by May 1996, with an
additional PHP 1,000,000 as interest. On October 28, 1995, they signed the agreement in Atty. Dennis
Perez's office, and Yu issued a check for PHP 3,500,000 while Uy issued a post-dated check for PHP
4,500,000. Uy's check was dishonored due to insufficient funds and incorrect dating (May 30, 1995,
instead of 1996), and Yu's efforts to contact Uy failed, leading to a demand letter on October 16, 1996.
HLURB confirmed no ongoing project by Uy's company in Cagayan de Oro. Testimonies from Yu, his wife
Patricia, and Atty. Wilfredo Imperial supported the prosecution, while Uy claimed it was a simple loan for
a Mindanao project. The prosecution presented exhibits A to G and H (HLURB certification), and the
defense presented exhibits 1 to 5 and a counter-affidavit. On June 17, 2004, Uy was convicted of Estafa
for failing to fulfill the investment agreement terms and issuing a dishonored check.

The petitioner argues that the Investment Agreement, central to his conviction, should not be
considered due to its status as a contract of adhesion. However, this argument does not absolve him of
responsibility. While a contract of adhesion is drafted by one party with the other merely agreeing to its
terms, it remains legally binding. Although such contracts can be deemed void if the weaker party is
unfairly treated and deprived of bargaining power, they are not inherently invalid. In this case, the
Investment Agreement between the petitioner and the complainant is deemed valid. Despite being
prepared by the complainant's lawyer, it included input from the petitioner. It is improbable that the
petitioner was unaware of its preparation, given his involvement in real estate development. Therefore,
his claim of ignorance regarding the agreement's details is unpersuasive.

Issue: WON the Investment Agreement, potentially labeled a contract of adhesion, can be invalidated
based on the petitioner's claim of non-involvement in its drafting, despite his engagement in real estate
development and purported input into its terms.

Ruling:
The court deems the Investment Agreement between the petitioner and the private complainant as
valid, despite its preparation by the complainant's lawyer. Considering the petitioner's involvement in
the real estate industry and the incorporation of his suggestions into the agreement, it is unlikely that he
was unaware of its preparation, given that it contained details known only to the property owner.
Therefore, as an experienced businessman in real estate development, his understanding and consent to
the agreement are presumed.

ACI Phil Inc. vs Conquia G.R No. 174466 July 14, 2008

Facts: Respondent Editha C. Coquia and petitioner ACI Philippines, Inc. entered into an agreement for
the purchase of flint cullets (glass scraps) at P4.20 per kilo under Purchase Order No. 106211, with
subsequent deliveries accepted and paid for at the same price. ACI later demanded a reduction in price,
to which respondent agreed, issuing Purchase Order No. 106373, but further demanded a price decrease
to P3.10 per kilo. Respondent filed a Complaint for specific performance and damages, seeking payment
at the renegotiated price of P3.65 per kilo and demanding acceptance and payment for remaining
deliveries. Petitioner, claiming the contract was based on prompt delivery assurances, presented
evidence rejected by trial and appellate courts. The courts ordered petitioner to accept deliveries under
Purchase Order No. 106211 and pay at P4.20 per kilo.

Issue: WON the PO was a contract of adhesion as what respondent contends

Ruling: In the case at bar, it is evident that the respondent, an experienced businesswoman who
regularly conducts transactions with large corporations, actively sought a contract with the petitioner
after learning of their need for flint cullets. Her involvement in significant business dealings, such as
being La Tondeña's sole buyer of cullets and obtaining loans from banks, indicates her astuteness and
financial acumen. Given these circumstances, there is no basis to apply the concept of contracts of
adhesion to the purchase orders involved. Additionally, the terms and conditions outlined in the
purchase orders, including those listed on the reverse side, do not demonstrate any unfair advantage or
one-sidedness in favor of the petitioner.

Phil Savings Bank vs Spouses Castillo G.R No. 193178 May 30, 2011

Facts:
The case involves Spouses Castillo and others who obtained a loan from PSB, secured by a real estate
mortgage, as evidenced by a promissory note containing a provision allowing PSB to adjust the interest
rate within lawful limits. PNB exercised this right, increasing and decreasing the interest rate over time,
with rates ranging from 15% to 29% per annum. Spouses Castillo did not contest these changes until they
requested a reduction, which PSB denied. They then filed a case for reformation of the instrument,
alleging that the interest rate increases were unreasonable, excessive, and arbitrary. The RTC ruled in
favor of Spouses Castillo, which was affirmed by the CA on appeal with modifications with regard to the
amount of interest in excess.

Issue: WON the unilateral increase of interest made by the bank is valid.
Ruling: The court held that the unilateral increases of the interest rate by PSB in INVALID. The unilateral
determination and imposition of the increased rates is violative of the principle of mutuality of contracts
under Art. 1308. The increase or decrease of interest rates hinges solely on the discretion of PSB. Any
contract which appears to be heavily weighed in favor of one of the parties so as to lead to an
unconscionable result, thus partaking of the nature of a contract of adhesion, is VOID. Any stipulation
regarding the validity or compliance of the contract left solely to the will of one of the parties is likewise
invalid.

Velez vs Ramas 40 Phil 787

Facts: The case involves Teodoro Velez and his wife, Hermenegilda Chiong Veloso,
suing Salomon Ramas and Roberto Quirante to recover money owed under a written
obligation signed by the defendants. The obligation arose from Restituta Quirante's
embezzlement of money from the plaintiffs' pawnshop, for which Ramas and
Quirante guaranteed payment to avoid legal action against Restituta. Ramas
admitted to the facts but argued that the contract was illegal. He also sought to
recover a partial payment he made. The trial court ruled in favor of the defendants,
absolving them from the complaint and awarding Ramas a counterclaim. The
plaintiffs appealed this decision.
Issue: WON the contract is valid
Ruling: The Court was not in favor of the validity of the contract. According to Article
1352 of the New Civil Code, contracts that lack a valid reason (No Cause) or have an
illegal reason (Unlawful Cause) are completely INVALID. The reason for a contract to
be illegal if it is contrary the law, moral values, accepted customs, public order, or
public policy. The Supreme Court agreed with the trial court's decision that there
was no legal basis for enforcing this contract. Therefore, they upheld the trial court's
ruling, and the appellants were ordered to cover the costs.

CONSENT AND ACCEPTANCE

Zayco vs Serra 44 Phil 326

FACTS: On November 7, 1918, plaintiff Lorenzo Zayco and defendant Salvador Serra entered into a
contract for the purchase of the Palma Central sugar central, which included clauses regarding the
purchase price, payment terms, and the expiration date of the option to purchase. On June 28, 1919,
Zayco sent a letter to Serra accepting the contract and offering a cash payment of P100,000. However,
on July 15, 1919, Serra informed Zayco that the contract was cancelled and annulled. Subsequently,
Zayco filed a lawsuit against Serra to compel him to execute the sale and pay damages

ISSUE: WON the acceptance of the offer was sufficient to convert it into a binding contract.
RULING: No. The court ruled that Zayco's acceptance involved a new proposition, namely the specific
amount of the first payment, which was not included in the offer. Therefore, the acceptance was not
sufficient to give life to the contract.

In order for an acceptance to convert an offer into a perfect contract, it must be plain and unconditional.

If it involves any new proposition, it will not be considered a valid acceptance.

Zayco's acceptance involved a proposal regarding the amount of the first payment, which was not
contained in the offer.

Therefore, Zayco's acceptance did not conform to the offer and did not give rise to a contract.

Montinola vs Victorias Milling 54 Phil 782

FACTS: Victorias Milling Co., Inc. organized a premium contest for the most efficient production of sugar
among its affiliated planters. The contest had strict rules, including a prohibition against delivering sugar
cane from one hacienda in the name of another, even if both plantations belonged to the same owner.
Ruperto Montinola, one of the principal planters, claimed that he was entitled to the most important
premiums but was disqualified by the management of the milling company for violating the rules.

ISSUE: whether the disqualification of Montinola by the management of the Victorias Milling Co., Inc. for
violating the contest rules is valid.

RULING: YES. The offerer of the reward has the right to impose any legal conditions on the offer, and all
conditions imposed are material elements of the offer and contract. In the case at bar, Montinola
violated the rule that prohibited delivering sugar cane from one hacienda in the name of another, even
if both plantations belonged to the same owner.

The court emphasized that in competitive contests for rewards, the acceptance must be in strict
conformity with the offer, and a qualified acceptance does not create a contract. Furthermore, The
court held that the findings of fact by the referee, unless there is fraud or misinterpretation of the
contest's terms and conditions, should not be disturbed by the courts, where in the case, there was
none.

Thus, the judgments in favor of Montinola were reversed, and the cases were dismissed.

Asian vs Jalandoni 45 Phil 296

FACTS: Luis Asiain proposed selling part of his "Maria" hacienda to Benjamin Jalandoni for P55,000,
citing 25-30 hectares of land with a 2,000 picul sugar cane yield. After agreeing to a memorandum for
roughly 25 hectares with the same yield, Jalandoni paid P30,000 and took possession. However, he later
found out the land was slightly over 18 hectares, yielding only 800 piculs of sugar. Consequently,
Jalandoni rescinded the contract.

ISSUE: WON the land sale contract should be rescinded due to a mutual mistake regarding the quantity
of land and crop.

RULING: Yes. The court ruled in favor of the buyer, Jalandoni, and rescinded the contract. The court
applied Article 1471 of the Civil Code, which provides that if land is sold within boundaries with an
expression of the area and if the area is grossly deficient, the vendee has the option to either have the
price reduced proportionately or to ask for the rescission of the contract.

In this case, there was a mutual mistake regarding the quantity of land, which went to the essence of
the contract, and therefore the contract could be rescinded.

The mutual mistake of the parties involved an erroneous belief regarding the size of the land and the
expected yield of the sugar crop. Luis Asiain mistakenly believed and represented that the tract of land
contained between 25 and 30 hectares and would yield 2,000 piculs of sugar, while Benjamin Jalandoni
relied on these assertions without verifying them independently and failing to exercise due diligence.

Martinez vs Hongkong Shanghai Bank 15 Phil 253

FACTS: Plaintiffs Mercedes Martinez y Fernandez and Alejandro S. Macleod entered into a
settlement agreement with defendants The Hongkong & Shanghai Banking Corporation and
Aldecoa & Co. to resolve various claims and disputes between them. The plaintiffs later claimed
their consent to the contract was given under duress and undue influence, as they were facing
civil and criminal actions related to alleged fraudulent activities and mismanagement of a
company. The defendants, however, argued that the plaintiffs entered into the settlement freely
and voluntarily.

ISSUE: Whether the contract should be set aside on the grounds of duress and undue influence.

RULING: No. The court ruled in favor of the defendants and upheld the validity of the contract.
The court found that the plaintiffs' consent to the contract was given freely and voluntarily, and
not under duress or undue influence.

ART. [Link] given under error, violence, intimidation, or deceit shall be

null.
ART. [Link] or intimidation shall annul the obligation, even though such
violence or intimidation shall have been used by a third person who did not take
part in the contract."
The court provides that it is necessary to distinguish between real duress and the
motive which is present when one gives his consent reluctantly. A contract is valid
even though one of the parties entered into it against his wishes and desires or
even against his better judgment.
In the case at bar,

 The court examined the facts of the case and found that the plaintiffs' allegations of duress
and undue influence were not sufficient to support their claim.

 The plaintiffs themselves initiated the negotiations for the settlement.

 The plaintiffs had the assistance of legal counsel and the advice of their family throughout the
process.

 The plaintiffs had a real question as to the validity of their claims to the properties involved in
the settlement.

 Their attorneys had advised them that their claims were unfounded.

 The court concluded that the plaintiffs had acted according to their own judgment and in their
best interest in entering into the settlement agreement.

Moreover, The court emphasized that not every contract made by a wife to relieve her husband from
the consequences of his crimes is voidable.

Thus, From the whole case were are of the opinion that the finding of the court below that the plaintiff
executed the contract in suit of her own free will and choice and not from duress is fully sustained by
the evidence.

The judgment of the court below is, therefore, affirmed with cost against the appellant. So ordered.

Naranja vs CA G.R No. 160132 April 17, 2009

FACTS: Roque Naranja, owner of Lot No. 4 and a one-third share in Lot No. 2, sold both properties to
Lucilia Belardo in 1981 via a deed of sale. This deed was not registered due to Belardo's financial
constraints. Roque later executed another deed of sale with Dema-ala to secure a loan, but he passed
away shortly thereafter. Belardo eventually paid off the loan and attempted to register the original deed
of sale. However, the children of Roque's co-owners contested this move, filing a case to nullify the deed
of sale and assert their ownership over the properties through Extrajudicial Settlement of Estate.

ISSUE:
 1. Whether or not the deed of sale is valid despite not containing a technical description of the
subject properties.

2. Whether or not the consent of Roque Naranja was vitiated, and if there was consideration and
proper notarization of the deed of sale.

RULING: The Supreme Court affirmed the decision of the Court of Appeals, upholding the validity of the
deed of sale and ordering the reconveyance of the subject property to Lucilia Belardo.

1. The Court held that a deed of sale does not need to contain a technical description of the
subject property to be valid. The essential requisites for a valid contract of sale are the consent
of the parties, a determinate object, and a price certain in money or its equivalent.

The deed of sale in question clearly identified the subject properties by indicating their
respective lot numbers, areas, and the certificates of title covering them.

The technical description can be referred to in the certificates of title.

2. The Court found that petitioners failed to provide sufficient proof that Roque's consent to the
sale was vitiated or that the deed of sale was simulated or without consideration.

The notarized document carries the evidentiary weight of its due execution.

There was no strong, complete, and conclusive proof of its falsity or nullity.

WHEREFORE, premises considered, the petition is DENIED. The Court of Appeals Decision dated
September 13, 2002 and Resolution dated September 24, 2003 are AFFIRMED

VOID CONTRACTS

E. Razon vs Phil Ports Authority 151 SCRA 233

Rodriguez vs Rodriguez 20 SCRA 908

Obot vs Sandadillas April 25, 1966

VOIDABLE CONTRACTS

Miailhe vs CA 354 SCRA 675

Dalay vs Aquitan 47 SCRA 951

FORMS

Dauden-Hernaez vs Delos Angeles 27 SCRA 276

Ong Chua vs Carr 53 Phil 975

E. Razon vs Phil Ports Authority 151 SCRA 233

Facts: In the case of E. Razon, Inc. v. Philippine Ports Authority (G.R. No. 75197), E. Razon, Inc. (ERI), also
known as Metro Port Service, Inc. (MPSI), had been awarded a contract in 1966 to operate arrastre
services at South Harbor, Manila, which was subsequently renewed several times, with the last renewal
being an eight-year term starting July 1, 1980. In 1978, Enrique Razon was coerced into transferring 60%
of ERI's shares to entities associated with President Marcos, specifically Alfredo "Bejo" Romualdez. On
July 18, 1986, the Philippine Ports Authority (PPA) issued a letter citing complaints and demanded a
response by the next day; however, on July 19, 1986, PPA unilaterally canceled the contract and
appointed Marina Port Services, Inc. (Marina) as interim operator. ERI filed for certiorari and sought a
restraining order in both the Supreme Court and the Regional Trial Court (RTC) of Manila, but the
Supreme Court dismissed the petition and imposed disciplinary actions against ERI’s lawyers for forum
shopping.

Issue: The main issue was whether the Philippine Ports Authority's unilateral cancellation of E. Razon,
Inc.'s management contract without prior hearing and investigation violated ERI's right to due process.

Ruling: The Supreme Court ruled that the management contract between E. Razon, Inc. (ERI) and the
Philippine Ports Authority (PPA) was null and void due to its association with Alfredo "Bejo" Romualdez,
which violated the Anti-Graft and Corrupt Practices Act. Romualdez, being closely related to then
President Marcos, was prohibited from engaging in any transactions with the government, rendering any
contracts involving him illegal. Consequently, the contract was deemed illegal from its inception under
Article 1409, paragraph 7, of the Civil Code, which nullifies contracts expressly prohibited by law. The
Court emphasized that no judicial action was necessary to annul a void contract, and thus, PPA had the
right to unilaterally cancel it without a prior hearing. Additionally, even if the contract were deemed
valid, ERI had committed serious violations, as alleged by PPA, justifying immediate termination.
Moreover, the Court upheld PPA's authority to manage port operations and determine the suitability of
Marina Port Services, Inc. as the interim operator. Therefore, the petition filed by ERI was dismissed, and
costs were imposed against the petitioners.

Rodriguez vs Rodriguez 20 SCRA 908

Concepcion Felix Vda. de Rodriguez, the widow of Don Felipe Calderon, entered into a second marriage
with Domingo Rodriguez. Prior to this marriage, Concepcion Felix owned two fishponds in Bulacan. On
January 24, 1934, she purportedly sold these properties to her daughter, Concepcion Calderon, for
P2,500. Subsequently, on January 27, 1934, her daughter transferred the properties back to Concepcion
Felix and Domingo Rodriguez. These transactions were notarized and registered, resulting in new titles
issued in the names of the spouses.
After Domingo Rodriguez's death, an extrajudicial settlement of his estate was made, allocating portions
of the fishponds to his heirs. Concepcion Felix was granted lifetime usufruct over a third of the
fishponds. Later, she leased the fishponds from the heirs for five years.

However, disputes arose when Concepcion Felix failed to deliver earnings from the fishponds to the
heirs, prompting legal action. Concepcion Felix then filed a case seeking nullification of the transactions
involving the fishponds.

Issue: Whether the contracts transferring ownership of the fishponds were valid, considering the
allegations of duress, simulation, and lack of consideration.

Ruling: The Supreme Court affirmed the lower court's decision, ruling against Concepcion Felix. While
there were claims of duress and lack of consideration, the court found insufficient evidence to support
these allegations. It deemed the contracts valid, rejecting the argument of simulation as the transactions
were intended to be real and effective. However, the court acknowledged that the contracts were
tainted by an illegal purpose - circumventing the law prohibiting donations between spouses. Citing
Article 1334 of the Civil Code of 1889, which prohibits such donations, the court declared the contracts
voidable. Nonetheless, under Article 1306 of the Civil Code, if both parties are guilty of an illegal act,
neither can enforce the contract. Moreover, the court applied the principle of laches, as Concepcion Felix
waited 28 years to contest the contracts despite knowing their potential nullity. This prolonged inaction,
coupled with her participation in subsequent transactions based on the assumption of the contracts'
validity, estopped her from challenging them. Therefore, the court upheld the validity of the contracts
and ruled against Concepcion Felix.

In the case of Concepcion Felix Vda. de Rodriguez vs. Geronimo Rodriguez et al., the donation to a
spouse was deemed invalid due to legal prohibitions against such transactions.

Under Article 1334 of the Civil Code of 1889, which was in force at the time of the transactions,
donations between spouses during marriage were prohibited. This prohibition aimed to prevent
potential abuse and manipulation of marital assets. The law sought to uphold the principle of fairness
and prevent situations where one spouse could unjustly enrich themselves at the expense of the other.

In this case, the transfers of ownership of the fishponds from Concepcion Felix to her daughter and then
back to Concepcion Felix and her husband, Domingo Rodriguez, were found to be aimed at
circumventing this prohibition. Although the transactions were intended to convert the properties from
separate to conjugal assets, thereby vesting a half interest in Domingo Rodriguez, they effectively
constituted donations between spouses.

Despite the apparent intentions behind the transactions, the court ruled that the contracts were tainted
by an illegal purpose - circumventing the law prohibiting donations between spouses. Consequently, the
contracts were deemed voidable under the provisions of Article 1306 of the Civil Code, which states that
when both parties are guilty of an illegal act, neither can enforce the contract or recover what was given
by virtue of the contract.
Therefore, the donation to the spouse was deemed invalid because it violated the legal prohibition
against such transactions, as stipulated in Article 1334 of the Civil Code of 1889.

VOIDABLE CONTRACTS

Miailhe vs CA 354 SCRA 675

Facts: William Alain Miailhe filed a complaint for annulment of sale, reconveyance, and damages against
the Republic of the Philippines and the Development Bank of the Philippines. Miailhe alleged that he and
his family were the former owners of three parcels of land in Manila, which were unlawfully taken by the
Republic through intimidation during the martial law regime of President Ferdinand Marcos. Despite
repeated demands for reconveyance, the defendants refused to return the properties.

Issue: Whether the action for the annulment of the Contract of Sale has prescribed.

Ruling: The Court ruled that Miailhe's action for the annulment of the Contract of Sale had prescribed.
Actions for the annulment of contracts prescribe in four years, starting from the time the defect in
consent ceases. In this case, the alleged threat and intimidation ceased when President Marcos left the
country on February 24, 1986. Therefore, the prescriptive period for filing the complaint ended on
February 24, 1990. Since Miailhe filed the complaint on March 23, 1990, more than four years had
elapsed, rendering his action time-barred.

Explanation: The ruling deemed Miailhe's action voidable due to intimidation during the martial law
regime. However, the Court held that the prescription period began when the alleged intimidation
ceased, which was when President Marcos left the country in 1986. Despite Miailhe's argument that
extrajudicial demands interrupted prescription, the Court found that such demands were not applicable
in the absence of an existing obligation. The Court emphasized that the Contract of Sale, though
allegedly voidable, was still binding until annulled by a court action. Therefore, Miailhe's action for
annulment was dismissed as time-barred.

The law that serves as the basis for the facts, issue, and ruling in the case of William Alain Miailhe vs.
Court of Appeals and Republic of the Philippines is primarily Article 1390 of the Civil Code of the
Philippines, which pertains to voidable contracts.

Article 1390 states that "The following contracts are voidable or annullable, even though there may have
been no damage to the contracting parties: (1) Those where one of the parties is incapable of giving
consent to a contract; (2) Those where the consent is vitiated by mistake, violence, intimidation, undue
influence or fraud."

This article establishes the legal principle that contracts entered into under certain conditions, such as
intimidation, are voidable. It provides the basis for Miailhe's claim for the annulment of the sale contract
due to intimidation during the martial law regime.

Additionally, Article 1155 of the Civil Code is referenced regarding the interruption of prescription.
Article 1155 states that "The prescription of actions is interrupted when they are filed before the court,
when there is an extrajudicial demand by the creditors, and when there is any written acknowledgment
of the debt by the debtor."

This article is cited in the ruling to address Miailhe's argument that his extrajudicial demands interrupted
the prescription period. However, the Court determined that extrajudicial demands were not applicable
in this case due to the absence of an existing obligation, as the Contract of Sale was still binding until
annulled by a proper court action.

These legal provisions provide the framework for understanding the facts, issue, and ruling of the case,
guiding the Court's decision-making process in resolving the dispute between the parties involved.