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Hernaez vs. de Los Angeles

This case involves an actress filing a complaint against a film production company to recover fees for her work in two films. The lower court dismissed the complaint because the agreement was not written down. However, the Supreme Court ruled that according to the Civil Code, contracts do not need to be in writing to be valid and enforceable, as long as the essential elements are present. The Code prioritizes upholding the spirit and intent of the parties over formalities. Therefore, oral contracts can be valid. The Supreme Court remanded the case back to the lower court to determine the actress' fees.

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65 views1 page

Hernaez vs. de Los Angeles

This case involves an actress filing a complaint against a film production company to recover fees for her work in two films. The lower court dismissed the complaint because the agreement was not written down. However, the Supreme Court ruled that according to the Civil Code, contracts do not need to be in writing to be valid and enforceable, as long as the essential elements are present. The Code prioritizes upholding the spirit and intent of the parties over formalities. Therefore, oral contracts can be valid. The Supreme Court remanded the case back to the lower court to determine the actress' fees.

Uploaded by

Raymund
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Abadiez, Raymund, C.

HERNAEZ vs. DE LOS ANGELES G.R. No. L-27010              

FACTS:

Petitioner, an actress, filed a complaint against Hollywood Far East Productions to recover fees for her services as
leading actress in two motion pictures produced by the company. Respondent judge, De los Angeles ordered the
complaint dismissed grounded on the reason that the “claim of plaintiff was not evidenced by any written document,
either public or private”. That according to Article 1358 governing unenforceable contracts, writing was absolute and
indispensable, because the amount involved exceeds five hundred pesos.

ISSUE:

WON said contract must be in writing to be valid and enforceable.

RULING:

No. The aforementioned contract needs not to be in writing.

Article 1315 of the Civil Code provides that: “Contracts are perfected by mere consent, and from that moment the
parties are bound not only to the fulfillment of what has been expressly stipulated but also to all the consequences
which, according to their nature, may be in keeping with good faith, usage and law.”

Furthermore Article 1356 of the same book provides that: “Contracts shall be obligatory in whatever form they may
have been entered into, provided all the essential requisites for their validity are present….” Exemptions to the
general rule are solemn contracts (needs to be in writing to be valid) and memorandums (governed by Article 1402(2)
of the Statute of Frauds).

In the matter of formalities, the contractual system of our Civil Code still follows the upholding of the spirit and intent
of the parties over formalities: hence, in general, contracts are valid and binding from their perfection regardless of
form whether they be oral or written. Petition is with merit and case remanded to lower court for fee determination.

Case Brief: This case is about the lower court ruling against an actress and the same dismissed her complaint on the
grounds that under Article 1358 governing unenforceable contracts, writing was absolute and indispensable since the
amount involved exceeds five hundred pesos. However it was reversed by the SC and was remanded because
according to them the contractual system of our Civil Code still follows the upholding of the spirit and intent of the
parties over formalities: hence, in general, contracts are valid and binding from their perfection regardless of form
whether they be oral or written. Further Article 1315 says contracts are perfected by mere consent and then Article
1356 of the same code Contracts shall be obligatory in whatever form they may have been entered into, provided all
the essential requisites for their validity are present which in this case are.

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