Saturday, September 24, 2016

Domalagan v. Bolifer 33 Phil 471; February 8, 1916

Domalagan v. Bolifer
Nature of the Case: Recover of the defendant the sum of P516, together with damages estimated in the sum of P350 and interest, and costs.

Doctrine: If the parties to an action, during the trial of the cause, make no objection to the admissibility of oral evidence to support contracts like the one in question and permit the contract to be proved, by evidence other than a writing, it will be just as binding upon the parties as if it had been reduced to writing.

Facts: Plaintiff alleged that, in the month of November, 1909, he and the defendant entered into a contract by virtue of the terms of which he was to pay to the defendant the sum of P500 upon the marriage of his son Cipriano Domalagan with the daughter of the defendant, Bonifacia Bolifer;

He completed his obligation under said contract by paying to the defendant the said sum of P500, together with the further sum of P16 "as hansel or token of future marriage," that, notwithstanding said agreement, the said Bonifacia Bolifer, in the month of August, 1910, was joined in lawful wedlock to Laureano Sisi.

He demanded of the defendant the return of the said sum of P516 together with the interest and damages; that the damages which he suffered resulted from the fact that he, in order to raise said sum of P500, was obliged to sell certain real property belonging to him, located in the Province of Bohol, at a great sacrifice.

Defendant presented a general denial. He also alleged that the facts stated in the complaint do not constitute a cause of action.

CFI: rendered a judgment in favor of the plaintiff and against the defendant in said sum of P516 together with the interest at the rate of 6 per cent from the 17th of December, 1910.

Issue: WON the verbal contract entered into by the plaintiff and the defendant in regard to the delivery of the money by reason of a prospective marriage is valid and effective

Ruling: YES
The appellant contends that a contract, such as the one relied upon by the plaintiff, in order to be valid, must be reduced to writing. We have examined the record in vain to find that the defendant during the trial of the cause objected to any proof or any part thereof, presented by the plaintiff, which showed or tended to show the existence of the alleged contract. That part of said section 335 which the appellant relies upon for relief provides:

"In the following cases an agreement hereafter made shall be unenforceable by action unless the same, or some note or memorandum thereof, be in writing, and subscribed by the party charged, or by his agent; evidence, therefore, of the agreement can not be received without the writing or secondary evidence of its contents:
"1.** * "2.** *
"3. An agreement made upon the consideration of marriage, other than a mutual promise to marry."

Said section (335) does not render oral contracts invalid. A contract may be valid and yet, by virtue of said section, the parties will be unable to prove it.

Said section provides that the contract shall not be enforced by an action unless the same is evidenced by some note or memorandum. Said section simply provides the method by which the contracts mentioned therein may be proved. It does not declare that said contracts are invalid, which have not been reduced to writing, except perhaps those mentioned in paragraph 5 of said section (335). A contract may be a perfectly valid contract even though it is not clothed with the necessary form. If it is not made in conformity with said section of course it cannot be proved, if proper objection is made. But a failure to except to evidence presented in order to prove the contract, because it does not conform to the statute, is a waiver of the provisions of the law.


If the parties to an action, during the trial of the cause, make no objection to the admissibility of oral evidence to support contracts like the one in question and permit the contract to be proved, by evidence other than a writing, it will be just as binding upon the parties as if it had been reduced to writing.

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