Pablo Palma v. Juan Cañizares · G.R. 34

Petitioner: Pablo Palma
Respondent: Juan Cañizares
Citation: G.R. No. 34
Court: Supreme Court En Banc
Division: En Banc
Ponente: Torres, J.
Decided: December 31, 1902

Summary

Pablo Palma sued Juan Cañizares for $4,500 on a promissory note that originated from a gambling debt. Cañizares had lost $5,000 to Saturnina Salazar in a monte game and executed a note through his attorney-in-fact Francisco Ong. After partial payment, Salazar assigned the remaining debt to Palma. The Supreme Court dismissed the action, holding that gambling debts from prohibited games like monte are unenforceable under Civil Code Article 1798, regardless of being formalized in a promissory note. The Court also found insufficient proof of Cañizares' consent to the assignment. This case establishes that illegal consideration voids contractual obligations, and proper subrogation requires debtor consent.

Statutes applied

Civil Code, Art. 1798

Related cases

Other Philippine cases on the same provisions and issues.

I. O. Conchegull v. Joseph B. Hyams G.R. No. 893
La Razon Social de Hijos de I. de La Rama v. Rosendo Lacson G.R. No. 1462
Alejandro Reyes v. Francisco Martinez G.R. No. 1724
Zoilo Garcia Vasquez v. P.B. Florence G.R. No. 2353
Rafael Azada y Lara v. Francisco Martinez y Garcia G.R. No. 4179

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By the Intellegal Editorial Board · December 31, 1902

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