Professional Documents
Culture Documents
vs.
JUAN CODINA ARENAS AND OTHERS, defendants;
VICENTE SIXTO VILLANUEVA, appellant
Case No. G.R. No. L-5921
Date of Promulgation July 25, 1911
Ponente ARELLANO, C.J. (En Banc)
Topic Presumption of capacity
ISSUES
WoN monomania of wealth necessarily warrants that the person does not have capacity to act.
December 15, 1908 Juan Codina Arenas and Francisco Lara del Pino, as principals, and Alipio
Locso, Vicente Sixto Villanueva and the Chinaman, Siy Ho, as sureties sign a bond in favor of
plaintiff for the obliged to pay the amount of P 3,305.76 at three months from date, with interest
at P 1.00 per month.
April 5, 1909 The plaintiff sued the debtors regarding the bond sign and was summoned, the
record showing that summons was served on Villanueva;
May 12, 1909 - Villanueva did not appear, and was declared in default.
Wife of Villanueva appeared when judgment was about to be executed and asked that he be
relieved from the bond and the judgment because he was insane (declared July 24, 1909) with
his wife as his guardian.
Case was reopened and tried and the evidence showed that Villanueva executed the bond with
full understanding of the nature and consequences of the act performed by him although he was
suffering from monomania of great wealth.
He was, therefore, held liable on the bond. Hence appealed to the Supreme Court.
RATIO DECIDENDI
ISSUE RATIO
WoN monomania of No.
wealth necessarily
warrants that the person SC affirmed the judgment of the CA. it would have been necessary to
does not have capacity to show that:
act. 1. Such monomania was habitual and constituted a veritable
mental perturbation in the patient;
2. That the bond executed was the result of such monomania, and
not the effect of any other cause, that is, that there were not, or could
there have been any other cause for the contract than the ostentation of
wealth and this was purely an effect of such monomania of wealth.
3. That the monomania existed on the date the bond in question
was executed. Monomania of wealth does not necessarily imply that the
person is incapable of executing a bond such as that in question.
4. Capacity to act must be supposed to attach to a person who has
not previously been declared incapable, and such capacity is presumed
to continue for so long as the contrary is not proved, that is, at the
moment of his acting he was incapable, crazy, insane, or out of his mind;
which, in the opinion of the court has not been proved in this case.
RULING
The judgment appealed from is affirmed, with the costs of this instance against the appellant. So
ordered.