Amparo Gonzalez v. Primitivo Trinidad

Summary

This case involves a simulated contract of sale where respondents Primitivo Trinidad and Maria Ynares executed a fictitious deed of sale to petitioners Amparo Gonzalez and Alfredo Trinidad to avoid property attachment. The P10,000 sale price was never paid, making the transaction simulated. The Court of First Instance declared it void under articles 1305-1306 of the Civil Code, but the Court of Appeals reversed on different grounds. The Supreme Court En Banc affirmed the Court of Appeals, ruling that articles 1305-1306 were inapplicable since the contract wasn't illegal but rather lacked consideration entirely. The Court distinguished between illegal motives (saving property from attachment) and absent consideration, holding the contract null and void per se under article 1261. This decision clarifies the important distinction between consideration and motives in contract law, establishing that simulation without actual consideration renders contracts void regardless of the parties' motives.