Facts: Lope Atienza filed a lawsuit against Maximino Castillo, Eulogia Giga, and Juana Castillo in the Court of First Instance of Tayabas, seeking to recover P1,836 as damages for an alleged breach of a marriage promise made by Maximino Castillo and Eulogia Giga regarding their daughter, Juana Castillo. Atienza claimed that there was an agreement between the parents that Juana Castillo would marry him and that he had rendered services to the defendants in consideration of this promise. During the trial, Atienza attempted to prove the existence of the marital agreement and his services through witness testimony. However, the defendants objected, citing Article 335 of the Code of Civil Procedure, which mandates that agreements concerning marriage cannot be proven by testimony alone without documentary evidence. The trial court upheld the defendants’ objection and dismissed the case due to Atienza’s lack of documentary evidence, leading to his appeal.
Issues:
1. Whether the alleged marital agreement could be proven through testimonial evidence.
2. Whether the defendants were barred from invoking the Statute of Frauds for failing to allege its provisions applicable to the case.
3. Whether the agreement falls under the prohibitions of the Statute of Frauds.
Court’s Decision:
The Supreme Court sided with the defendants, confirming that the case sustained the defendants’ position. The action by Atienza was not to compel Juana Castillo into marriage but to claim damages for breach of a marriage promise and services rendered in consideration of that promise. The Court ruled that the case falls within the Statute of Frauds, requiring contracts not to be performed within a year from their making to be proven in court by documentary—and not merely testimonial—evidence. It noted that the defendants could not have pre-emptively addressed the lack of written evidence for the agreement in their initial pleadings since it was only revealed during the trial that the agreement was not documented. The decision also touched upon the agreement’s timing, which stipulated the marriage to occur four years after its making, underscoring the requirement for written proof for such agreements. The appellate’s sentence was affirmed in all respects.
Doctrine:
The case reaffirmed the application of the Statute of Frauds to agreements relating to marriage, specifically highlighting the requirement for such agreements to have documentary evidence if they are not to be performed within one year from the making of the agreement. It emphasizes the legal principle that oral evidence is insufficient to prove agreements that fall under the Statute of Frauds.
Class Notes:
1. Statute of Frauds: Requires certain contracts (e.g., those not to be performed within one year from their making) to be in writing to be enforceable.
2. Evidence in Marriage Agreements: Documentary evidence is crucial for agreements involving marriage, especially when performance (i.e., the marriage) is set beyond one year from the agreement’s date.
3. Procedural posture in presenting evidence: The timing and nature of the evidence (documentary vs. testimonial) can critically impact the case’s outcome, especially in matters falling under the Statute of Frauds.
Historical Background:
This case illustrates the Philippine judiciary’s stringent adherence to the Statute of Frauds during early to mid-20th century civil litigation. It underscores the period’s legal philosophy requiring formal documentation for significant agreements, reflecting a broader legal tradition that prioritizes written contracts over oral agreements in specific contexts, including promises of marriage. The decision also highlights the conservative approach towards marriage engagements, underscoring the importance of formal commitments under the law.
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