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Law on Obligations and Contracts

Unenforceable Contracts

Civil Code Art. 1403-1408

ALCOSER, MYRNA

APOSTOL, ROLDAN

AUTENTICO, MARIA LOURDES

BALAOD, LENDY MEE

BATERNA, FEVY JANE

BUALAN, JOVENIEL

BULI, GENIE

CABILES, CRISTINE

CUÑADO, DANIEL

Bachelor of Science in Business Administration

St. John Paul II College of Davao

BACC106: Obligations and Contracts

Mr. Vicco Gerona Piodos

April 28, 2022

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UNENFORCEABLE CONTRACT

Legal Definition

The Civil Code provides that a contract is unenforceable when it is “entered

into in the name of another person by one who has been given no authority or legal

representation, or who has acted beyond his powers.”[ Article 1403, paragraph 1,

Civil Code] And that “(a) contract entered into in the name of another by one who

has no authority or legal representation, or who has acted beyond his powers, shall

be unenforceable [Article 1317, paragraph 2, Supra.].” It is a basic axiom in civil

law embodied in our Civil Code that no one may contract in the name of another

without being authorized by the latter, or unless he has by law a right to represent

him.[Art. 1317, Civil Code of the Philippines] A contract entered into in the name

of another by one who has no authority or legal representation, or who has acted

beyond his powers, shall be unenforceable, unless it is ratified, expressly or

impliedly, by the person on whose behalf it has been executed, before it is revoked

by the other contracting party.

Article 1403 of the same Code also provide. "The following contracts are

unenforceable, unless they are ratified: " Those entered into in the name of another

person by one who has been given no authority or legal representation or who has

acted beyond his powers."

Out of the above given principles, sprung the creation and acceptance of the

relationship of agency whereby one party, called the principal (mandante),

authorizes another, called the agent (mandatario), to act for and in his behalf in

transactions with third persons. The essential elements of agency are: there is

consent, express or implied, of the parties to establish the relationship; the object

is the execution of a juridical act in relation to a third person; (Art. 1317, Civil Code

of the Philippines) the agent acts as a representative and not for himself; and the

agent acts within the scope of his authority [ Art. 1868, Civil Code].
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Acosta (2021), explained that unenforceable contract is a lawful contract

that the court refuses to enforce, unless it is ratified, expressly or impliedly, by the

person on behalf of its that has been executed, before it is revoked by the other

contracting faction. In contrast to void and voidable, the term unenforceable is

frequently employed. The agreement will be legitimate if the parties follow it, but

if they don't, the court will have no power to compel them.

Aldeguer (2014), also expressed that according to the civil code,

unenforceable contracts are valid but imperfect because they cannot be enforced

in courts.

Examples of unenforceable contracts as stipulate in Article 1403 of the civil code

are as follows:

1. Those entered into in the name of another who has been given no control

or legal representation or who has acted beyond his powers.

2. Those that do not obey under the Statute of Frauds (The items covered

must appear in writing otherwise it cannot be enforced in courts.)

➢ An agreement that by its terms is not to be performed within a year

from the making thereof;

➢ A special promise to answer for the debt, default, or miscarriage of

another;

➢ An agreement made in consideration of marriage, other than a

mutual promise to marry;

➢ An agreement for the sale of goods, chattels or things in action, at a

price not less than five hundred pesos, unless the buyer accept and

receive part of such goods and chattels, or the evidences, or some of

them, of such things in action or pay at the time some part of the

purchase money; but when a sale is made by auction and entry is

made by the auctioneer in his sales book, at the time of the sale, of

the amount and kind of property sold, terms of sale, price, names of
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the purchasers and person on whose account the sale is made, it is a

sufficient memorandum;

➢ Sale of real property

➢ An agreement for the leasing for a longer period than one year.

3. Those where both parties are incapacitated of giving consent to a

contract.

Those covered under the Statute of Frauds refer only to executory

contracts, and does not refer to executed contracts already.

Coverage of Unenforceable Contract

In a material constructed by Vanni (2020) who suggested that to determine

if a contract is unenforceable, it is important to first understand what a contract is

and what makes an agreement legally enforceable. The bargained-for exchange is

known as consideration. Perhaps, consideration can be anything from services to

money, as long as it is adequate and fairly induces the other party to assent to the

terms. If the contract falls under the Statute of Frauds, as many business contracts

do, it should be in writing and signed by both parties.

Potential Issues to Determine Unenforceable Contracts

In signing a contract can have significant consequences for both parties. It

is essential to understand the circumstances that could render a contract

unenforceable. By being on vigilant prior to the signing, you can identify any

possible red flags ahead of time, which can prevent the need for costly court

intervention. Here are some of the most usual issues that can render a contract

unenforceable.

• Lack of Capacity. For a contract to be enforceable, both parties should

have the capacity to understand the terms of the contract. What makes a

contract unenforceable is when one party does not understand the means

or how they will be bound by it. Lack of capacity commonly applies to

minors (children under the age of 18), mentally ill individuals, or people

under the impact of drugs or alcohol. For example, a person agony from
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mental impairment may lack the capacity to enter into a contract. Even a

person who was intoxicated at the time they signed a contract may not have

the extent to do so. Another typical example is when minors enter into a

contract without the overseeing of a parent or guardian. Under these

circumstances, the contract may be unenforceable.

• Duress or Undue Influence. Parties should agree to the terms of the

contract willingly. For a contract to be enforceable, one side cannot feel

forced or pressured into signing the contract. Duress is defined as a coercive

action that leaves the party with no other another other than to sign the

agreement. In this context, a contract could be deemed unenforceable if one

party intimidate a lawsuit unless the other party signs. For example, a

shipper (Company A) agreed to transport a certain amount of Company B's

materials, which would be used in a major development project. After

Company B's project was commenced and Company A's ship was en route

with the materials, Company A reject to complete the trip unless Company

B agreed to pay a higher price. Company B was enforced to pay the jacked-

up rate because there was no other way to get the material, and not

completing the job might lead to unsustainable losses. The court ultimately

seen that this agreement to raise the price was not enforceable, because it

came over through duress. Another usual example of duress is blackmail.

excessive influence is a bit subtler and more centered around a power

dynamic. If one party is in a special relationship with the other that

influence their ability to decide to sign the contract willingly, the agreement

is unenforceable. For example, if Person B forced Person A to enter into an

agreement by taking advantage of a special or particularly persuasive

relationship that Person B had with Person A, the resulting contract might

be seen as unenforceable on grounds of excessive influence. In general, to

prove excessive influence, Person A would have to show that Person B used

excessive pressure against Person A during the bargaining process and that
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for whatever reason Person A was overly susceptible to the duress tactics or

that Person B exploited a confidential relationship to exert pressure on

Person A.

• Misrepresentation. Misrepresentation occurs when one party

deliberately (this is considered fraudulent) or unknowingly (this is

considered negligent) makes an untrue statement with the intent to

convince the other party to sign the contract. For example, Company A

faulty tells a vendor they will not hire a competing business if they sign the

contract. Meanwhile, Company A has a meeting with a competitor the next

day and plans to enter into business with them. Company A would have

performed fraudulent misrepresentation, which renders the contract

unenforceable.

Remember: All the time include all terms of the contract in writing

• Other Issues That Can Render an Unenforceable Contract Del

(Puerto, J. 2021);

• Unconscionability

A contract is considered unconscionable when something over its terms or

how it was formed is so unfair that it would “shock the conscience” if it were

enforced. A contract is not unconscionable just because one party had further

bargaining power. Employment contracts, for example, are routinely seen

enforceable even though the employer usually has more power to shape the terms

of the agreement. Contracts have been seen unconscionable in situations where a

very sophisticated business took advantage of a barely literate, uneducated

customer.

Depending on the situation, a court would decide the entire agreement is

unenforceable or might just strike the parts it considers unconscionable from the

agreement and enforce the rest of the contract.

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• Public Policy, Illegality

Courts don’t enforce contracts that agree to anything against the law

or the best interest of the public. For example, courts will not enforce an

agreement to buy illegal drugs nor will court enforce a landlord-tenant

agreement that needs a tenant to agree to live in conditions that do not

meet health and safety code essentials. The purpose of public policy and

illegality grounds for non-enforcement is to protect the society as a

whole.

• Mistake

Not all mistakes make a contract unenforceable but few will.

Mistakes can be “unilateral,” where only one party assemble a mistake

about the contract or “mutual.” Contracts are more likely to be

considered unenforceable where the mistake is mutual but occasionally

even a unilateral mistake can serve as a basis for not enforcing a

contract. Only mistakes that are significant to the agreement and

influenced its creation or performance in a significant way can make a

contract unenforceable. For example, the other party may give you the

wrong contract and you do not know until after you sign it. In this

circumstance, the court may cancel the contract and deem it

unenforceable if the parties have not done so themselves.

• Impossibility

Sometimes a contract that was valid when formed becomes

impossible to carry out and for this basis, will be unenforceable.

Impossibility that is the fault of one party generally does not make a

contract unenforceable. For example, if Company A contracts to sell 20

barrels of its flour to Company B and a natural disaster ravage out

Company A's entire stock of flour before the sale can be finished,
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Company A might be able to have the contract ruled unenforceable on

grounds of impracticality.

In the context of the Civil Code of the Philippines, Chapter 8.

“Unenforceable Contracts” as presented in the Official Gazette of the Philippine

Govenrment;

Article 1403. The following contracts are unenforceable, unless they are

ratified:

(1) Those entered into in the name of another person by one who has been

given no authority or legal representation, or who has acted beyond his

powers;

(2) Those that do not comply with the Statute of Frauds as set forth in this

number. In the following cases an agreement hereafter made shall be

unenforceable by action, unless the same, or some note or memorandum,

thereof, be in writing, and subscribed by the party charged, or by his agent;

evidence, therefore, of the agreement cannot be received without the

writing, or secondary evidence of its contents:

(a) An agreement that by its terms is not to be performed within a

year from the making thereof;

(b) A special promise to answer for the debt, default, or miscarriage

of another;

(c) An agreement made in consideration of marriage, other than a

mutual promise to marry;

(d) An agreement for the sale of goods, chattels or things in action,

at a price not less than five hundred pesos, unless the buyer accept

and receive part of such goods and chattels, or the evidences, or some

of them, of such things in action or pay at the time some part of the

purchase money; but when a sale is made by auction and entry is

made by the auctioneer in his sales book, at the time of the sale, of
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the amount and kind of property sold, terms of sale, price, names of

the purchasers and person on whose account the sale is made, it is a

sufficient memorandum;

(e) An agreement of the leasing for a longer period than one year, or

for the sale of real property or of an interest therein;

(f) A representation as to the credit of a third person.

(3) Those where both parties are incapable of giving consent to a contract.

Article 1404.

• Unauthorized contracts are governed by Article 1317 and the principles of

agency in Title X of this Book.

• In relation to Article 1317, no one may contract in the name of another

without the consent of whose behalf the agent is representing.

Article 1405.

• Contracts infringing the Statute of Frauds, referred to in No. 2 of Article

1403, are ratified by the failure to object to the presentation of oral

evidence to prove the same, or by the acceptance of benefit under them.

Unenforceable contracts (paragraph 2, Article 1403: Statute of Frauds) may be

ratified in two ways:

1. Failure to object to the presentation of oral evidence. This is tantamount

to a waiver. Contracts that are infringed in the Statute of Frauds are ratified

by the failure to object to the presentation of parol evidence and are

enforceable.

2. Acceptance of Benefits under these contacts is equivalent to waiver or

estoppel; only applies to executor contracts. If the oral contract was

reduced into writing by the party charged, this exercise is called

recognition. It is the express ratification of the contract.

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If the party in whose favor the statute may be invoked, cross examined the

witness who is testifying on the oral contract, the former is deemed to have waived

the right to object to the admission of the testimonial evidence.

The party should promptly object to the presentation of the witness once it

becomes apparent that no evidence in writing could be presented to prove the

contract. The objection must be invoked during the “offer of the testimony” of the

witness or a motion to dismiss may be filed before answer to the complaint is filed.

Article 1406.

• When a contract is enforceable under the Statute of Frauds, and a public

document is necessary for its registration in the Registry of Deeds, the

parties may avail themselves of the right under Article 1357.

Article 1407.

In a contract where both parties are incapable of giving consent, express or

implied ratification by the parent or guardian, as the case may be, of one of the

contracting parties shall give the contract the same effect as if only one of them

were incapacitated. If ratification is made by the parents or guardians, as the case,

of both contracting parties, the contract shall be validated from the inception. For

example, when Pia heard from a relative that her grandfather will give her special

gems this December through a friend, since she was incapable to receive them

because of the inability to detect colors well, her guardian will be the one to approve

whether or not the item was same as the description that her grandfather.

Article 1408 (Del Puerto, 2021)

• Unenforceable contracts cannot be assailed by third persons.

• Strangers to a voidable contract cannot bring an action to annul the same

(see Art. 1397.); neither can they assail a contract because of its
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unenforceability. The benefit of the Statute can only be claimed or waived

by one who is a party or privy to the oral contract, not by a stranger.

Under Article 1403, the following contracts are unenforceable:

(1) Those entered into in the name of another by one without

or acting in excess of authority;

(2) Those that do not comply with the Statute of Frauds; and

(3) Those where both parties are incapable of giving consent.

A party to an unenforceable contract may bring an action to enforce

it subject to the defense of the lack of the required form (Statute of

Kinds of unenforceable contracts.

Under Article 1403, the following contracts are unenforceable:

(1) Those entered into in the name of another by one without

or acting in excess of authority;

(2) Those that do not comply with the Statute of Frauds; and

(3) Those where both parties are incapable of giving consent.

A party to an unenforceable contract may bring an action to enforce

it subject to the defense of the lack of the required form (Statute of

Kinds of Unenforceable Contracts

Under Article 1403, the following contracts are unenforceable:

(1) Those entered into in the name of another by one without or acting in excess of

authority;

(2) Those that do not comply with the Statute of Frauds; and

(3) Those where both parties are incapable of giving consent. A party to an

unenforceable contract may bring an action to enforce it subject to the defense of

the lack of the required form (Statute of Frauds) or absence of authority or in

excess thereof. The law expressly provides that such a contract cannot be assailed

by a third person.
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Statute of Frauds

The term “statute of frauds’’ is descriptive of statutes that require certain

classes of contracts to be in writing. This statute does not deprive the parties of the

right to contract with respect to the matters therein involved, but merely regulates

the formalities of the contract necessary to render it enforceable. The effect of non-

compliance is simply that no action can be proved unless the requirement is

complied with. Thus, they are included in the provisions of the New Civil Code

regarding unenforceable contracts, more particularly Art.1403(2).

The purpose of the statute is to prevent fraud and perjury in the

enforcement of obligations depending for their evidence on the unassisted memory

of witnesses by requiring certain enumerated contracts and transactions to be

evidenced by a writing signed by the party to be charged. It was not designed to

further or perpetuate fraud. Accordingly, its application is limited. It makes only

ineffective actions for specific performance of the contracts covered by it; it does

not declare them absolutely void and of no effect. As explicitly provided for in the

above-quoted paragraph (2), Article 1403 of the Civil Code, the contracts

concerned are simply "unenforceable" and the requirement that they — or some

note or memorandum thereof — be in writing refers only to the manner they are to

be proved (LawPhil, 1992)..

Where the statute of frauds necessitates a written contract, it does not

typically require the contract to be a formal document. Any type of written

agreement that is reasonably clear and signed by the appropriate parties will

usually suffice, as long as it meets the following conditions (CFI, 2022):

• The written document must contain the essential terms of the contract,

such as the price to be paid for goods received.

• The parties to the contract must be clearly identified in the contract.

• It must also be signed – preferably by both parties to the contract but, at

minimum, by the party against whom the enforcement of the contract is

being sought.
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The Effect of Statute of Frauds

A statute of frauds does not of itself render a contract void. The statute

makes certain contracts “voidable” by one of the parties, in the event that the party

does not wish to follow through on the agreement.

Differences of Contracts

DEFECTIVE CONTRACTS’ DIFFERENCES

VALID BINDING ENFORCEABLE

RECISSIBLE YES YES YES

VOIDABLE YES YES YES

UNENFORCEABLE YES NO NO

VOID NO NO NO

The table above shows that, unenforceable contract’s main difference from

other defective contracts is that unenforceable contact remains valid although it is

neither binding nor enforceable. However, void contract is a contract that is

completely invalid, binding and enforceable. While unenforceable contract

remains valid, there is a chance that the contact will be cured from its defectiveness

such until it is ratified. When a contract is void, by all means, has no effect and

both parties cannot perform nor demand anything since it is an absolute rule that

void contracts can never be valid.

DEFECTIVE CONTRACTS’ DIFFERENCES

RECISSIBLE VOIDABLE UNENFORCEABLE VOID

Why Causes Consent is Lack of Authority Missing

defective? Damage to defective or Form Essential

3rd party Elements

Can be Yes Yes Yes No

ratified?
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Applicable Art. 1381 Art. 1390 Art. 1403 Art. 1409

provisions

Remedy to Rescission Annulment N/A N/A

avoid

• An unenforceable contract is one that, for lack of authority or of the required

writing, or for the incompetence of both parties, cannot be given effect unless

properly ratified.

• A voidable contract is one in which the consent of one party is defective,

either because of want of capacity or because consent is vitiated.

• A rescissible contract is one, which, though possessing all the essential

requisites of contracts, has caused a particular economic damage either to one of

the contracting parties or to a third person.

• A void contract is one that suffers from the absence of an object or cause and

is, therefore, an absolute nullity and produces no effect

• As per indicated under unenforceable of why defective does this

unenforceable contract through the reason of lack of authority or form and it can

also be ratified in which the difference is the chance to make it fully valid through

ratification unlike from void contract that there is no exemption to be valid.

• Under the unenforceable and void contracts there was no indicated remedy

to be avoided or invalidate in the first place these two defective contracts have no

effect in which it is not bound and not enforceable.

Remedy

Unenforceable contracts are also subject to ratification according to the civil

law. A contract may be rendered perfectly valid by ratification, which can be

express or implied. Implied ratification may take the form of accepting and
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retaining the benefits of a contract (Metropolitan Waterworks and Sewerage

System (MWSS) vs. Court of Appeals, 297 SCRA 287, 307 (1998).

In order to be recognized in a legal sense, a ratification must be:

➢ Intelligent

➢ Voluntary

➢ Deliberate

UNENFORCEABLE CONTRACT CASE DIGEST

[ G.R. No.L-24332, January 31, 1978 ]

RAMON RALLOS, ADMINISTRATOR OF THE ESTATE OF

CONCEPCION RALLOS, PETITIONER, VS. FELIX GO CHAN AND

SONS REALTY CORPORATION AND COURT OF APPEALS,

RESPONDENTS.

This is a case of an attorney-in-fact, Simeon Rallos, who after the death of his

principal, Concepcion Rallos, sold the latter's undivided share in a parcel of land

pursuant to a special power of attorney which the principal had executed in his

favor. The administrator of the estate of the deceased principal went to court to

have the sale declared unenforceable and to recover the disposed share. The trial

court granted the relief prayed for, but upon appeal, the Court of Appeals upheld

the validity of the sale and dismissed the complaint.

The following facts are not disputed:

Concepcion and Gerundia both surnamed Rallos were sisters and registered

co-owners of a parcel of land known as Lot No. 5983 of the Cadastral Survey of

Cebu covered by Transfer Certificate of Title No. 11118 of the Registry of Cebu. On

April 21, 1954, the sisters executed a special power of attorney in favor of their

brother, Simeon Rallos, authorizing him to sell for and in their behalf lot 5983. On

March 3, 1955, Concepcion Rallos died. On September 12, 1955, Simeon Rallos sold

the undivided shares of his sisters Concepcion and Gerundia in lot 5983 to Felix
 16

Go Chan & Sons Realty Corporation for the sum of P10,686.90. The deed of sale

was registered in the Registry of Deeds of Cebu, TCT No. 11118 was cancelled, and

a new Transfer Certificate of Title No. 12989 was issued in the name of the vendee.

ISSUE/S:

After trial, the court a quo rendered judgment with the following dispositive

portion:

"A. On Plaintiff's Complaint

(1) Declaring the deed of sale, Exh. 'C', null and void insofar as the one-half pro-

indiviso share of Concepcion Rallos in the property in question, - Lot 5983 of the

Cadastral Survey of Cebu - is concerned;

(2) Ordering the Register of Deeds of Cebu City to cancel Transfer Certificate of

Title No. 12989 covering Lot 5983 and to issue in lieu thereof another in the names

of FELIX GO CHAN & SONS REALTY CORPORATION and the Estate of

Concepcion Rallos in the proportion of one-half (1/2) share each pro-indiviso;

(3) Ordering Felix Go Chan & Sons Realty Corporation to deliver the possession of

an undivided one-half (1/2) share of Lot 5983 to the herein plaintiff;

(4) Sentencing the defendant Juan T. Borromeo, administrator of the Estate of

Simeon Rallos, to pay to plaintiff in concept of reasonable attorney's fees the sum

of P1,000.00; and

(5) Ordering both defendants to pay the costs jointly and severally.

"B. On GO CHAN'S Cross-Claim:

(1) Sentencing the co-defendant Juan T. Borromeo, administrator of the Estate of

Simeon Rallos, to pay to defendant Felix Go Chan & Sons Realty Corporation the

sum of P5,343.45, representing the price of one-half (1/2) share of lot 5983;
 17

(2) Ordering co-defendant Juan T. Borromeo, administrator of the Estate of

Simeon Rallos, to pay in concept of reasonable attorney's fees to Felix Go Chan &

Sons Realty Corporation the sum of P500.00.

"C. On Third-Party Complaint of defendant Juan T. Borromeo, administrator of

Estate of Simeon Rallos, against Josefina Rallos, special administratrix of the

Estate of Gerundia Rallos:

(1) Dismissing the third-party complaint without prejudice to filing either a

complaint against the regular administrator of the Estate of Gerundia Rallos or a

claim in the Intestate-Estate of Gerundia Rallos, covering the same subject-matter

of the third-party complaint, at bar." (Record on Appeal)

Holding’s:

It is a basic axiom in civil law embodied in our Civil Code that no one may

contract in the name of another without being authorized by the latter, or unless

he has by law a right to represent him. A contract entered into in the name of

another by one who has no authority or legal representation, or who has acted

beyond his powers, shall be unenforceable, unless it is ratified, expressly or

impliedly, by the person on whose behalf it has been executed, before it is revoked

by the other contracting party. Article 1403 of the same Code also provides:

"ART. 1403. The following contracts are unenforceable, unless they are ratified:

"(1) Those entered into in the name of another person by one who has been given

no authority or legal representation or who has acted beyond his powers." Out of

the above given principles, sprung the creation and acceptance of the relationship

of agency whereby one party, called the principal (mandante), authorizes another,

called the agent (mandatario), to act for and in his behalf in transactions with third

persons. The essential elements of agency are: (1) there is consent, express or

implied, of the parties to establish the relationship; (2) the object is the execution
 18

of a juridical act in relation to a third person; (3) the agent acts as a representative

and not for himself; and (4) the agent acts within the scope of his authority.

Agency is basically personal, representative, and derivative in nature. The

authority of the agent to act emanates from the powers granted to him by his

principal; his act is the act of the principal if done within the scope of the authority.

Qui facit per alium facit per se. "He who acts through another acts himself."

2. There are various ways of extinguishing agency, but here We are concerned only

with one cause-death of the principal. Paragraph 3 of Art. 1919 of the Civil Code

which was taken from Art. 1709 of the Spanish Civil Code provides:

"ART. 1919. Agency is extinguished:

"3. By the death, civil interdiction, insanity or insolvency of the principal or of the

agent."

By reason of the very nature of the relationship between principal and agent,

agency is extinguished by the death of the principal or of the agent. This is the law

in this jurisdiction.[8]

DECISION OF THE SUPREME COURT:

IN VIEW OF ALL THE FOREGOING, We set aside the decision of respondent

appellate court, and We affirm en toto the judgment rendered by then Hon.

Amador E. Gomez of the Court of First Instance of Cebu, with costs against

respondent realty corporation at all instances.

SO ORDERED.

Teehankee, (Chairman), Makasiar, Fernandez, and Guerrero, JJ., concur.

In this case;

The sale of the land was declared unenforceable by the supreme court lead by Chief

Justice Teehanke.
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References:

Acosta, P. (2021). Unenforceable Contract. Retrieved from:

https://www.manilatimes.net/2021/09/18/legal-advice/unenforceable-
contract/1815196
Akawnting (2020) Unenforceable Contract from the Civil Code of the Philippines.
Retrieved from: https://youtu.be/H-AB_VAi4Ps
Aldeguer, C. (2014). Law on Obligations and Contracts in the Philippines.
Retrieved from:
https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2429979
Del Puerto, J. (2021) DEFECTIVE CONTRACTS. Retrieved from:
https://barmentor.ph/library/e- defective-contracts
Foobarph (2007). Unenforceable Contracts; Articles 1403-1408 of the New Civil.
Retrieved from:
https://legalnotes.wordpress.com/2007/03/02/unenforceable-contracts/
Philippine Government official Gazette (1949). Civil Code of the Philippines.
https://www.officialgazette.gov.ph/downloads/1949/06jun/19490618-
RA-0386-JPL.pdf
Supreme Court E-Library (2015). Ramon Rallos Vs. Felix Go Chan and Sons Realty
Corporation and Court of Appeals. [G.R. No. L-24332, January 31, 1978]
https://elibrary.judiciary.gov.ph/elibsearch
Supreme Court E-Library (2014). Julieta V. Esguerra, Petitioner, Vs. Court
of Appeals and Sureste Properties, Inc., Respodents. [G.R. No. 119310,
February 03, 1997]. Retrieved from
https://elibrary.judiciary.gov.ph/elibsearch
Supreme Court (2002). Francisco Vs. Herrera [G.R. No. 139982 November 21,
2002. Retrieved from:
https://lawphil.net/judjuris/juri2002/nov2002/gr_139982_2002.html
Rich Stim (2022) Unenforceable Contracts: What to Watch Out For. Retrieved
from:
https://www.nolo.com/legal-encyclopedia/unenforceable-contracts-tips-
33079.html