Jean Polo E.

Nepomuceno, 152165

MARLENE DAUDEN-HERNAEZ, petitioner, vs. HON. WALFRIDO DE LOS ANGELES, Judge of the Court of
First Instance of Quezon City, HOLLYWOOD FAR EAST PRODUCTIONS, INC., and RAMON VALENZUELA,
respondents,

(No. L-27010; April 30, 1969)

When the law requires that a contract be in some form in order that it may be valid or enforceable; Art.
1356

FACTS:

Marlene Dauden-Hernaez was an actress who worked for Hollywood Far East Productions,
having acted in 2 movies for them. She filed a complaint against the latter and its President, Ramon
Valenzuela, as they had not paid her for her services.

The respondent court ruled that claim of Dauden-Hernaez cannot be sustained as there was no
written evidence of the contract. Thus leading to this appeal to the Supreme Court.

ISSUE:

Whether or not the contract between Dauden-Hernaez and Hollywood Far East Productions, Inc.
is valid.

RULING:

The Supreme Court ruled that, based on Art. 1356 of the Civil Code, a contract may be
enforceable in whatever form they were entered into. The only exception to this is where the law
requires a specific form of the contract or when the law requires that it should be proved by some
writing. The contract for compensation of services entered into by the parties does not fall under either
of the exceptions, and is therefore valid despite not being in written form.

The Philippine Contractual System follows that of the Spanish Civil Code and of the
Ordenamiento de Alcala” where contracts are valid and binding from their perfection regardless of the
form.

DISPOSITIVE:

WHEREFORE, the order dismissing the complaint is set aside, and the case is ordered remanded
to the court of origin for further proceedings not at variance with this decision. Costs to be solidarily
paid by private respondents Hollywood Far East Productions, Inc., and Ramon Valenzuela.