G.R. No. 1293 : February 23, 1904
ILDEFONSO DORONILA, plaintiff-appellant, vs. JOSE LOPEZ, guardian of the minor children of Don Pablo Ledesma, defendant-appellee.

FACTS:
Ildefonso Doronila was appointed guardian of the minor heirs of Pablo Ledesma. In February 1899, during the American landing in Iloilo, Doronila fled Jaro, leaving behind documents and funds of the estate in a safe. He later claimed these were lost. Upon his return, he failed to render an accounting of his guardianship despite requests. The family council removed him and appointed Jose Lopez as the new guardian. Lopez petitioned the superior provost court (exercising the powers of a Court of First Instance) to compel Doronila to account and deliver the estate’s property. The court ordered Doronila to comply. For his continued failure, the court found him in contempt and ordered his imprisonment. While imprisoned under poor conditions, Doronila was informed he would remain incarcerated until he complied. After a day, he was brought before the court, and a settlement was proposed. Following negotiations and a second brief imprisonment for non-compliance, Doronila, joined by his wife, executed a contract on December 22, 1900. In it, he agreed to pay 12,000 pesos or renew lost credit documents and assume a 4,000-peso debt of the estate, securing these obligations with a mortgage on properties. Doronila later sought to annul this contract, alleging his consent was vitiated by violence and intimidation under Article 1267 of the Civil Code, as he signed it under fear of imprisonment.

ISSUE:
Whether the contract executed by Doronila is voidable on the ground that his consent was obtained through violence or intimidation (duress) as defined under the Civil Code.

RULING:
No. The Supreme Court affirmed the judgment of the Court of First Instance dismissing Doronila’s petition for annulment. The Court held that the fear which motivated Doronila to sign the contractthe fear of being imprisoned for contempt due to his failure to obey a lawful court order to render an accountingdid not constitute the duress contemplated by law to invalidate a contract. The intimidation was not illicit; it was the lawful consequence of his own disobedience to a valid court order. The court’s order required him to account, not specifically to execute the contract. His compliance with the court order would have relieved him from imprisonment irrespective of the contract. Therefore, the contract, being a compromise to avoid the compelled accounting, was not procured by the type of intimidation that warrants annulment. The findings of fact did not establish the requisite vice of consent under Article 1267 of the Civil Code.