Standard Oil Co. of NY v.

Arenas
G.R. No. 5921, July 25, 1911
Topic: Presumption of Capacity
Ponente: Arellano, J.

Doctrine: “Capacity to act must be presumed to attach to every person who has not been
previously declared to be incapable, and to continue until the contrary is proven, that is
until it is shown that, at the moment of acting, the person in question was actually
incapacitated, insane or out of his mind.”

Facts:
On Dec 15, 1908, Juan Codina Arenas & Francisco Lara del Pino (principals), and
Alipio Locso, Vincente Sixto Villanueva and Siy Ho (Chinaman) as sureties, assumed the
obligation to pay, jointly and severally to Standard Oil Co. (SOC), the sum of P 3,305.76,
at 3 months from date with interest at P1 per month.
Thereafter, SOC sues the debtors for the payment with interests from 15th Dec 1908
and costs; The CFI of Manila sentenced them to pay the amount jointly and severally.
While the judgement was pending execution. Elisa Torres de Villanueva, wife of
Vicente Sixto Villanueva, appeared and alleges that his husband was declared insane by
CFI Manila and that she was appointed as the guardian of the same court. She further
alleges that she was authorized by the court to annul several bonds given by her husband
while in a state of insanity.
The court granted the petition and the trial was reopened for the introduction of
evidence. The decision however held against the petitions holding Villanueva liable and
his acts as valid and efficacious. Another petition was filed by Villanueva himself but
sustained its decision. Hence this case.

Issue: Whether Villanueva was incapacitated at the time he executed the bonds with
SOC?

Held: No. “it is very evident that it cannot be concluded therefrom that, on Dec 16, 1908,
when Villanueva subscribed the obligation now contested, he did not possess the necessary
capacity to give efficient consent with respect to the bond which he freely executed.”

Ratio:
“Capacity to act must be presumed to attach to every person who has not been
previously declared to be incapable, and to continue until the contrary is proven, that is
until it is shown that, at the moment of acting, the person in question was actually
incapacitated, insane or out of his mind.”
The court has not found proof of the error of its judgment. It would have
been necessary to show such monomania was habitual and constituted a veritable mental
perturbation in the patient that the bond executed by the defendant Villanueva was the
result of such monomania. and not the effect of any other cause, that is, that there was not,
nor could there have been any other cause for the contract than an ostentation of wealth
and this purely an effect of such monomania of wealth; and that the monomania existed
on the date when the bond in question was executed.
The trial court, although it conceded as a fact that the defendant had for several
years suffered from such monomania, decided, however, guided by the medico-legal
doctrine cited, that a person's believing himself to be what he is not or his taking
a mere illusion for a reality is not necessarily a positive proof of insanity or
incapacity to bind himself in a contract. Specifically, about this case, the following
facts were brought out in the testimony given by the physicians, Don Rudesino Guervo and
Don Gervasio de Ocampo, witnesses for the defendant, the worrst of whom had visited
him some eight times during the years 1902 and 1903, and the latter, only once, in 1908.