Potenciano Ramirez v. Ma. Cecilia Ramirez

Summary

Father sued daughter to annul property transfer documents (Deed of Donation and Waiver of Possessory Rights) allegedly executed by him and his deceased wife. The wife had died in 1991 but documents were dated 1993 and 1995, making her signatures forgeries. Both trial and appellate courts found forgery but held parties in pari delicto under wrong Civil Code provision. Supreme Court corrected the applicable law to Article 1411 since forgery constitutes criminal offense, and found the cause of donation was illegal - to evade publication expenses and inheritance taxes due upon wife's death. Court held both parties in pari delicto, denying relief to either party and leaving them as they were when case was filed. Case demonstrates that parties to illegal contracts involving criminal acts cannot seek court assistance.