FACTS
Vicenta Jalbuena, wife of Ildefonso Doronila, brought an action to annul an undertaking wherein she pledged her separate individual property as security for an obligation of her husband to Gabriel Ledesma, as president of the Ledesma family council. Jalbuena alleged that her signature was procured through intimidation. Her husband, Doronila, had been acting as tutor for minor children of the Ledesma family. He was cited before the provost court on petition of the defendant Lopez to surrender papers and render accounts. An agreement was reached where Doronila accepted responsibility for lost papers valued at P12,000 and assumed an estate obligation of P4,000. The family council ratified this agreement, with an additional condition that Doronila provide security for P16,000 if the missing papers were not produced within six months. Doronila was subsequently ordered by the provost judge to give additional security. Failing to do so, he was committed to jail. As his own property was already encumbered, Doronila’s wife, Vicenta, who was present, was induced to join in the undertaking. Vicenta testified that the provost judge threatened to put her husband back in jail if she did not obligate her property as security, and that she signed out of fear for her husband’s punishment and potential deportation. The interpreter’s testimony corroborated that the provost judge told Vicenta to sign or her husband would be sent back to jail. Although the signing occurred eight days after the initial threat, the court found that the prolonged session of the court and the parties’ prior experience with its vigorous procedure meant the threat retained its coercive effect. The court also noted that the provost court’s jurisdiction was limited to cases not exceeding P5,000 Mexican dollars, and the matter at hand, involving an estate of over P103,000 and Doronila’s accountability for substantial sums, clearly exceeded this limit.

ISSUE
Whether or not the undertaking signed by Vicenta Jalbuena to secure her husband’s obligation is null and void due to intimidation and the lack of jurisdiction of the provost court.

RULING
Yes, the undertaking is null and void. The court found that Vicenta Jalbuena’s signature was procured through intimidation, as she was threatened with her husband’s re-imprisonment if she did not sign. This intimidation, coupled with the threat of legal prosecution of her husband, constituted a valid ground for annulling the obligation under Article 1268 of the Civil Code. Furthermore, the provost court lacked jurisdiction over the matter, as the value of the estate and Doronila’s financial accountability significantly exceeded the statutory limit of P5,000 Mexican dollars. The provost judge’s order for imprisonment was also void as it was beyond his power under the circumstances and was not authorized by Spanish law or principles of equity and justice. Consequently, the contract entered into by Vicenta Jalbuena is declared null and set aside.