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SYLVIA LICHAUCO DE LEON v. CA

FACTS:

The case involves a petition for review on certiorari filed by Sylvia Lichauco De Leon, seeking to reverse the decision of the Court of Appeals affirming the decision of the Regional Trial Court of Pasig. The petition arose from the dissolution of the marriage between Sylvia and Jose Vicente De Leon, which was followed by a de facto separation between the spouses. Sylvia, who had obtained American citizenship, filed for dissolution of marriage in the United States, but chose to hold in abeyance the divorce proceedings due to Jose Vicente's lack of assets in the United States. In March 1977, Sylvia entered into a Letter-Agreement with Jose Vicente's mother, Macaria De Leon, wherein Macaria agreed to deliver certain properties to Sylvia and to make cash payments. Sylvia and Jose Vicente also filed a joint petition for judicial approval of the dissolution of their conjugal partnership. Macaria fulfilled her obligations under the Letter-Agreement by making cash payments to Sylvia.

In this case, Sylvia Lichauco De Leon filed a petition for the dissolution of her conjugal partnership with Jose Vicente De Leon. They entered into a Letter-Agreement which stated that Sylvia would be awarded certain properties and assets while Jose Vicente fully assumed responsibility for any liens or encumbrances on the properties. The trial court approved the petition and dissolved the conjugal partnership. Sylvia then moved for the execution of the order, but Jose Vicente filed a motion for reconsideration alleging that Sylvia made a verbal reformation of the petition. Macaria De Leon, claiming ownership of the properties involved, filed a motion to intervene which was granted. The case was transferred to the Regional Trial Court of Pasig. The trial court rendered judgment declaring the Letter-Agreement null and void and ordering Sylvia to restore the amount she received from the agreement to Macaria. The trial court also affirmed the dissolution of the conjugal partnership and awarded Sylvia certain properties, except those owned by Macaria. Sylvia appealed to the Court of Appeals, which affirmed the decision. Sylvia then filed the present petition.

Sylvia and Jose Vicente entered into a Letter-Agreement to terminate their property relations. Sylvia argues that the consideration for her execution of the agreement was the termination of property relations with her husband. They subsequently filed a joint petition for the dissolution of their conjugal partnership. On the other hand, Macaria and Jose Vicente contend that the consideration was the termination of the marital relationship. The trial court noted that the letter agreement included provisions for a judicial separation of property and divorce proceedings, indicating that the parties intended not only the termination of property relations but also the termination of the entire marital relationship.

ISSUES:

  1. Whether the consideration for the execution of the Letter-Agreement was the termination of property relations or the termination of marital relationship.

  2. Whether the Letter-Agreement is void for being contrary to law, morals, and public policy.

  3. Whether the Letter-Agreement for the dissolution of the conjugal partnership of gains is void under Article 221 of the Civil Code.

  4. Whether the Letter-Agreement is ambiguous and should be construed against the party who caused the ambiguity.

  5. Whether Sylvia can recover what she has given by reason of the Letter-Agreement.

  6. Whether the contract between Macaria and Sylvia is valid despite the vices of consent of mistake and intimidation.

  7. Whether the pari delicto rule applies, thereby denying remedy to either party.

  8. Whether Article 1414 of the Civil Code is applicable in this case.

  9. Whether or not the accused was denied the right to a speedy trial.

  10. Whether or not the delay in the disposition of the case was attributable to the prosecution.

  11. Whether or not the right to a speedy trial was violated.

RULING:

  1. The consideration for the execution of the Letter-Agreement was the termination of the marital relationship between Jose Vicente and Sylvia, as evidenced by the statement in the agreement that the divorce proceedings will continue.

  2. The Letter-Agreement is void for being contrary to law, morals, and public policy. The court held that the termination of the marital relationship as consideration in the agreement is not only contrary to law but also contrary to Filipino morals and public policy. Marriage is not just a contract, but a sacred social institution governed by law and not subject to stipulations.

  3. Yes, the Letter-Agreement for the dissolution of the conjugal partnership of gains is void under Article 221 of the Civil Code.

  4. Yes, the Letter-Agreement is ambiguous and should be construed against Sylvia, the party who caused the ambiguity.

  5. No, Sylvia cannot recover what she has given by reason of the Letter-Agreement.

  6. The contract between Macaria and Sylvia is voidable due to the vices of consent of mistake and intimidation. However, the Court finds that the alleged intimidation and mistake do not meet the requirements provided by law to vitiate consent.

  7. The pari delicto rule does not apply in this case. Although both parties acted in violation of the law, the Court applies Article 1414 of the Civil Code, which allows the party repudiating the contract to recover the money or property if the purpose has not been accomplished and if it serves the public interest.

  8. Article 1414 of the Civil Code is applicable in this case, as it allows Macaria to recover the money or property since the contract was repudiated before the purpose was accomplished and adhering to the pari delicto rule would encourage circumvention of the law.

  9. No. The Court held that the accused was not denied the right to a speedy trial. It found that the delay in the disposition of the case was caused by the accused himself, as he had filed numerous motions and had even absented himself during trial.

  10. No. The Court ruled that the delay in the disposition of the case was not attributable to the prosecution. It noted that the prosecution had diligently pursued the case and had even filed all the necessary pleadings on time.

  11. No. The Court ruled that the accused's right to a speedy trial was not violated. It emphasized that the right to a speedy trial should not be used as a shield to prevent the prosecution from presenting its evidence and pursuing its case.

PRINCIPLES:

  • Contracts with considerations that are contrary to law, morals, good customs, public order or public policy are void and inexistent from the beginning.

  • Marriage is not a mere contract but an inviolable social institution. Its nature, consequences, and incidents are governed by law and not subject to stipulations.

  • Contracts based on unlawful considerations and contrary to public policy should be deemed null and void.

  • Article 191 of the Civil Code contemplates properties belonging to the spouses and not those belonging to a third party.

  • Contracts that are contrary to law or public policy are void and of no effect.

  • In case of ambiguity in a contract, it is construed against the party who caused the ambiguity.

  • A party cannot recover what has been given under an agreement that is void under the law.

  • Contracts where consent is given through mistake, violence, intimidation, undue influence, or fraud are voidable. (Article 1330, Civil Code)

  • For mistake to invalidate consent, it should refer to the substance of the thing or conditions which have principally moved one or both parties to enter into a contract. (Article 1331, Civil Code)

  • Intimidation that can vitiate consent must meet certain requirements: determination cause of the contract, unjust or unlawful threatened act, real and serious threat, evident disproportion between the evil and resistance, and reasonable and well-grounded fear. (Article 1335, Civil Code)

  • Pari delicto rule denies remedies to parties in an illegal agreement. (Ex dolo malo non oritur actio and In pari delicto potior est conditio defendentis)

  • Exception to the pari delicto rule is found in Article 1414 of the Civil Code, allowing repudiation of a contract and recovery of money or property if the purpose has not been accomplished and it serves the public interest.

  • Right to a speedy trial - The accused has the right to a speedy trial, which includes the right to a prompt disposition of the case. However, this right should not be used as a means to delay the proceedings or prevent the prosecution from pursuing its case.

  • Delay attributable to the accused - If the delay in the disposition of the case is caused by the accused himself, he cannot claim that his right to a speedy trial has been violated.

  • Diligence of the prosecution - The prosecution has the duty to diligently pursue the case and ensure a prompt disposition. If the delay in the disposition of the case is not attributable to the prosecution, the accused cannot argue that his right to a speedy trial has been violated.