Carrillo v. Jaojoco and Jaojoco
Art. 39. The following circumstances, among others, modify or limit capacity to act: age, insanity, imbecility, the state of being a deaf-mute, penalty, prodigality, family relations, alienage, absence, insolvency and trusteeship. The consequences of these circumstances are governed in this Code, other codes, the Rules of Court, and in special laws. Capacity to act is not limited on account of religious belief or political opinion.
In this case, Miguela Carrillo, as sister of deceased Adriana Carrillo and current administratrix of the latter’s estate, brought action to the CFI Cavite for the annulment of the document of because her sister was declared mentally incapacitated nine days after the transaction. She was confined in the hospital (and was there for the duration of the period) a month before the transaction occurred. The issue was whether or not Adriana was mentally incapacitated at the time the document of sale was executed.
The plaintiff’s attempt to prove that Adriana was mentally deranged was insufficient. Being confined in a hospital does not prove insanity. Her doctor testified that her sickness did not affect her head but only ½ of her body. Documents produced before the Court before the execution of the document of sale, shows complex tasks done by Adriana which couldn’t be done by a mentally incapacitated person.
