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    Frenzel Vs Catito GR143958

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    Pam Otic-Reyes
    This case involves a dispute over properties purchased in the Philippines by Alfred Frenzel, an Australian citizen, for Ederlina Catito while they were in a relationship. Alfred argued he is entitled to recover the properties since their relationship ended. However, the court ruled that any contract for Alfred to purchase properties is void as aliens were prohibited from land ownership. As the parties knowingly entered an illegal contract, Alfred has no right to recover the properties or claim unjust enrichment since one cannot benefit from their own illegal act. The court affirmed the lower courts' dismissal of Alfred's case.

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    © All Rights Reserved
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    Frenzel Vs Catito GR143958

    Uploaded by

    Pam Otic-Reyes
    289 views2 pages
    This case involves a dispute over properties purchased in the Philippines by Alfred Frenzel, an Australian citizen, for Ederlina Catito while they were in a relationship. Alfred argued he is entitled to recover the properties since their relationship ended. However, the court ruled that any contract for Alfred to purchase properties is void as aliens were prohibited from land ownership. As the parties knowingly entered an illegal contract, Alfred has no right to recover the properties or claim unjust enrichment since one cannot benefit from their own illegal act. The court affirmed the lower courts' dismissal of Alfred's case.

    Original Title

    Frenzel_vs_Catito_GR143958

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    This case involves a dispute over properties purchased in the Philippines by Alfred Frenzel, an Australian citizen, for Ederlina Catito while they were in a relationship. Alfred argued he is entitled to recover the properties since their relationship ended. However, the court ruled that any contract for Alfred to purchase properties is void as aliens were prohibited from land ownership. As the parties knowingly entered an illegal contract, Alfred has no right to recover the properties or claim unjust enrichment since one cannot benefit from their own illegal act. The court affirmed the lower courts' dismissal of Alfred's case.

    Copyright:

    © All Rights Reserved
    Download as ODT, PDF, TXT or read online from Scribd
    Download as odt, pdf, or txt
    289 views2 pages

    Frenzel Vs Catito GR143958

    Uploaded by

    Pam Otic-Reyes
    This case involves a dispute over properties purchased in the Philippines by Alfred Frenzel, an Australian citizen, for Ederlina Catito while they were in a relationship. Alfred argued he is entitled to recover the properties since their relationship ended. However, the court ruled that any contract for Alfred to purchase properties is void as aliens were prohibited from land ownership. As the parties knowingly entered an illegal contract, Alfred has no right to recover the properties or claim unjust enrichment since one cannot benefit from their own illegal act. The court affirmed the lower courts' dismissal of Alfred's case.

    Copyright:

    © All Rights Reserved
    Download as ODT, PDF, TXT or read online from Scribd
    Download as odt, pdf, or txt
    of 2

    FRENZEL v.

    CATITO
    GR No. 143958
    July 11, 2003

    Doctrine: Void for being against public policy; - a contract which violates the Constitution
    and the laws is void and vests no rights and creates no obligations. It does not produce any
    legal effect.

    FACTS:

    Petitioner Alfred Fritz Frenzel is an Australian citizen of German descent who was
    married to Teresita Santos, a Filipino citizen. He works as a pilot for New Guinea Airlines. On
    the other hand, private respondent Ederlina P. Catito was married to Klaus Muller, a German
    national. She worked as a masseuse in the King’s Cross nightclub in Sydney, Australia. The
    two met when Alfred went on a vacation in Sydney. They met again and this time, Alfred was
    able to convince Ederlina to stop working and to go back to the Philippines.

    When she returned to the Philippines, she was given money by Alfred to put up a
    beauty salon. Later on, he also gave money to her to be able to purchase a house and lot in
    San Francisco del Monte, Quezon City. Since he was aware that aliens were prohibited to
    purchase lands, he agreed to have Ederlina as the sole vendee. Later also, they opened two
    bank accounts with the Hong Kong and Shanghai Banking Corporation in Kowloon, Hong
    Kong. In addition, there were subsequent purchases of other real and personal properties.
    These were made on the anticipation on the part of Alfred that he and Ederlina will get
    married soon. However, this failed to materialize because of the fact that Ederlina was still
    married to Klaus. Ederlina failed to secure a divorce from Klaus. This exasperated Alfred and
    eventually their relationship started to fade. Thus, Alfred filed a complaint before the RTC of
    Davao City for recovery of real and personal properties. He demanded from Ederlina that
    she return all the money that were used to purchase the properties and also the properties
    which were bought, especially the house and lot and three other lots. However, the
    complaint of Alfred was dismissed by the RTC. On appeal, the Court of Appeals affirmed the
    decision of the RTC in toto.

    ISSUE:

    Whether or not Alfred is entitled to recover the said properties.

    RULING:

    No. The contention of petitioner Frenzel that to bar him from recovering the properties
    would be in violation of Article 22 of the Civil Code on unjust enrichment holds no water. It
    must be remembered that a contract which violates the Constitution and the laws is void
    and vests no rights and creates no obligations. It does not produce any legal effect. His
    reliance on Article 22 is misplaced because in this case, the action is proscribed by the
    Constitution or the parties are in pari delicto. This is founded on the general principles of
    public policy. It must be remembered that Alfred knew all along that he was disqualified
    from purchasing lands. His contention that he entered into the transaction because he was
    expecting that he and Ederlina will get married in the future is not a valid one. He also knew
    that he cannot get married to Ederlina because he still had a valid existing marriage with
    Teresita Santos

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