Sps. Rufino Angel v. Simplicio Aledo

Summary

This construction contract dispute arose when spouses Angel contracted with government employee Modales who used his father-in-law Aledo as dummy contractor to circumvent prohibition on government employees from contracting. After completion, Aledo sued for unpaid balance while Angels counterclaimed for construction defects. The trial court initially ruled for Angels, but Court of Appeals and Supreme Court reversed, holding the contracts were illegal and contrary to public policy. Under Article 1412 of the Civil Code, parties were found in pari delicto and left without remedy against each other. The case demonstrates the strict application of the illegal contract doctrine and the principle that courts will not aid parties to unlawful agreements.