Bambalan v.

Maramba
G.R. No. L-27710
January 30, 1928
Romualdez, J.

SUBJECT MATTER:
Civil Personality: Capacity to Act and Restrictions Thereon

DOCTRINE(S):
● Article 38. Minority, insanity or imbecility, the state of being a deaf-mute, prodigality and civil interdiction are mere
restrictions on capacity to act, and do not exempt the incapacitated person from certain obligations, as when the latter
arise from his acts or from property relations, such as easements.
● Article 1327. The following cannot give consent to a contract:
(1) Unemancipated minors;
(2) Insane or demented persons, and deaf-mutes who do not know how to write. (1263a)
● Article 1390. The following contracts are voidable or annullable, even though there may have been no damage to the
contracting parties:
(1) Those where one of the parties is incapable of giving consent to a contract;
(2) Those where the consent is vitiated by mistake, violence, intimidation, undue influence or fraud.

ACTION BEFORE THE SUPREME COURT:

Petition for certiorari

Petitioner(s): ISIDRO BAMBALAN Y PRADO, plaintiff-appellant

Parties Pedro C. Quinto for plaintiff-appellant

Respondent(s): GERMAN MARAMBA and GENOVEVA MUERONG, defendants-appellants

Turner, Rheberg and Sanchez for defendants-appellants

SUMMARY:
The plaintiff, Isidro Bambalan y Prado, signed a document dated July 17, 1922 as proof of selling a land he inherited from his
deceased father to the defendants. The plaintiff claims that while he has signed such document, he had only done so since his
mother, Paula Prado, was being intimidated by Genoveva Muerong, one of the defendants, with imprisonment. The Supreme Court
held that the sale is void because Bambalan was still a minor when he signed such document. The defendants knew of the
plaintiff’s age when he signed the document since the defendants were the ones who purchased his first cedula used to
acknowledge the document. The ruling in Mercado v. Espiritu cannot be applied in this case because the plaintiff didn’t misrepresent
himself.

ANTECEDENT FACTS:
● The plaintiff’s mother, Paula Prado, and her second husband Vicente Lagera, received a certain amount of money from
Genoveva Muerong in 1915.
● Deceased Isidro Bambalan y Colcotura left the plaintiff, Isidro Bambalan y Prado, as his sole and universal heir.
● Bambalan signed the document but claims he only did so since Genoveva Murong intimidated his mother by threatening
her with imprisonment.
● The defendants purchased the plaintiff’s first cedula which was used to acknowledge the document of the sale.

ISSUE(S) AND HOLDING(S):

1. W/N the sale of the land was valid -- NO

RATIO:
C2023(SALAZAR) - LAW 100, PANGALANGAN
 1. The defendants cannot claim ignorance of the plaintiff’s age when the plaintiff signed the document since the defendants
were the ones to purchase his first cedula acknowledgement of the document.
2. The doctrine used in Mercado v. Espiritu cannot be used as a precedent in this case.
○ The minor in such case presented himself to be of age. In the case of Bambalan v. Maramba, the defendants were
well-aware of the fact that plaintiff is of minor age during which he signed the document.

DISPOSITIVE:
● In view of the foregoing, the dispositive part of the decision appealed from is hereby affirmed, without any express findings
as to the costs in this instance. So ordered.

C2023(SALAZAR) - LAW 100, PANGALANGAN