Petitioner
Spouses Victor
Respondent
Lucia P. Ong
Citation
G.R. No. 207176
Court
Supreme Court
Division
First Division
Ponente
Reyes, J.
Decided
June 18, 2014

Summary

Spouses Binua sought nullification of real estate mortgages executed to secure Edna's debt after her estafa conviction, claiming duress and intimidation. The Supreme Court denied their petition, ruling that the mortgages were validly executed. The Court emphasized that a prior RTC decision finding only civil liability (based on a promissory note that novated the criminal obligation) was final and executory. Applying Article 1335 of the Civil Code, the Court found no intimidation since the respondent's act of enforcing a legal claim through competent authority was just and lawful. The threat of imprisonment from a valid conviction does not constitute the unjust act required to vitiate consent under the law. The decision reinforces the principle that contracts cannot be invalidated simply because one party faced legal consequences from lawful judicial processes.

Statutes applied

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By the Intellegal Editorial Board · June 18, 2014

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