Professional Documents
Culture Documents
TITLE III
NATURAL OBLIGATIONS
Provision: Article 1423. Obligations are civil or natural. Civil obligations give a right of action
to compel their performance. Natural obligations, not being based on positive law but on equity
and natural law, do not grant a right of action to enforce their performance, but after voluntary
fulfillment by the obligor, they authorize the retention of what has been delivered or rendered by
reason thereof. Some natural obligations are set forth in the following articles.
Explanation/Example:
The provision defines what constitutes a "natural obligation" and how it differs from a "civil
obligation."
Natural obligations Civil obligations
Article 1432. The principles of estoppel are hereby adopted insofar as they are not in
conflict with the provisions of this Code, the Code of Commerce, the Rules of Court and
special laws.
Effect of the General Principles of Estoppel
The principles of Estoppel are only suppletory.
Pleading of Alleged Estoppel
If facts are alleged as constituting estoppel, they must be expressly pleaded.
Article 1434. When a person who is not the owner of a thing sells or alienates and delivers
it, and later the seller or grantor acquires title thereto, such title passes by operation of law
to the buyer or grantee.
-When a person sells or alienates a property or thing not yet in his possession of ownership
but later on acquires ownership or title over that same property, its title or ownership
passes effectively to the transferee or vendee.
Article 1435. If a person in representation of another sells or alienates a thing, the former
cannot subsequently set up his own title as against the buyer or grantee.
Article 1436. A lessee or a bailee is estopped from asserting title to the thing leased or
received, as against the lessor or bailor.
Estoppel against tenant or bailee.
A tenant will not be heard to dispute his landlord’s title. (see Lizada vs. Omanan, 59 Phil.
547 [1934].) This estoppel applies even though the lessor had no title at the time the
relation of lessor and lessee was created, and may be asserted not only by the original
lessor, but also by those who succeed to his title. (Geminiano vs. Court of Appeals, 259
SCRA 344 [1996].) Under the Rules of Court, conclusive presumptions include: “(b) The
tenant is not permitted to deny the title of his landlord at the time of the commencement
of the relation of landlord and tenant between them.” (Sec. 3-b, Rule 131, Rules of
Court.) (2) Similarly, a bailee in commodatum (see Art. 1933.), depositum (see Art.
1962.), or pledge (see Art. 2093.) is estopped to assert title to the thing received as against
the bailor.
Example:
Nancy Vinay is a tenant in a land owned by Chess Escudero. Under Art. 1436, Nancy’s
acceptance of a tenancy relationship is an acknowledgement of Chess Escudero’s ownership of
the land and therefore she is barred from claiming title over that land.
Article 1437. When in a contract between third persons concerning immovable property,
one of them is misled by a person with respect to the ownership or real right over the real
estate, the latter is precluded from asserting his legal title or interest therein, provided all
these requisites are present:
(1) There must be fraudulent representation or wrongful concealment of facts known to the
party estopped;
(2) The party precluded must intend that the other should act upon the facts as
misrepresented;
(3) The party misled must have been unaware of the true facts; and
(4) The party defrauded must have acted in accordance with the misrepresentation.
Article 1438. One who has allowed another to assume apparent ownership of personal
property for the purpose of making any transfer of it, cannot, if he received the sum for
which a pledge has been constituted, set up his own title to defeat the pledge of the
property, made by the other to a pledgee who received the same in good faith and for value.
This article applies only to personal property. It deals with estoppel by acceptance of benefits. It
is based upon the acceptance and retention by one having knowledge or notice of the facts, of
benefits from a transaction, contract or statute which he might have rejected or contested.
Example:
Victor owns a car and he needs a loan but he loathe to make one. So he makes it appear by a
deed of donation that his friend Randolf is the car’s owner. It is then Randolf who executes a
chattel mortgage on the car turning over the proceeds of the mortgage to Victor. When Victor has
received the proceeds he is estopped from assailing the validity of the mortgage by asserting that
he is the factual owner of the car.
Article 1439. Estoppel is effective only as between the parties thereto or their successors in
interest.
Persons Bound by Estoppel
Both parties are, however, bound such as parties to a sale. Successors-in-interest (as well as
privies and grantees) are bound but third parties are not.