Short answer. Yes. Under Civil Code Article 1186, when the obligor voluntarily prevents a condition from being fulfilled, the law treats the condition as having been met. The debtor cannot use their own wrongful act to escape an obligation — the condition is constructively fulfilled, and the obligation becomes demandable.
What the law says
The condition shall be deemed fulfilled when the obligor voluntarily prevents its fulfillment.
Civil Code, Article 1186 — Constructive Fulfillment. Read the full provision →
Why the law steps in when the debtor interferes
A conditional obligation is one where performance depends on the happening of a future, uncertain event. When a debtor engineers the non-occurrence of that event to avoid paying, they are exploiting a loophole in a way the law will not permit. Article 1186 closes that loophole with a single rule: if the obligor voluntarily prevents the condition from being fulfilled, the condition is deemed fulfilled anyway. The obligation becomes enforceable as if the event had actually happened.
What 'voluntarily' means — and what it does not
The word voluntarily is the critical qualifier. The debtor must have acted deliberately to prevent the condition — not merely by chance, not because of circumstances beyond their control, and not as an incidental result of doing something else entirely. A debtor who genuinely could not prevent the outcome, or who acted in good faith on grounds unrelated to escaping the obligation, does not trigger Article 1186. The doctrine is aimed at bad faith interference, not at every case where the debtor's conduct happens to coincide with the condition failing.
Practical examples of constructive fulfillment
Suppose a contract provides that the seller must deliver goods if the buyer secures a credit line from a named bank. The seller, not wanting to deliver, contacts the bank and persuades it to deny the application. Under Article 1186, the condition — securing the credit line — is deemed fulfilled. The seller cannot then say there is no obligation because no credit line was issued. The same principle applies when a buyer prevents an appraisal that would trigger a price adjustment, or when a debtor sabotages the occurrence of any event that would require them to pay.
The obligation becomes fully demandable
Once constructive fulfillment is established, the legal position is the same as if the condition had genuinely occurred on the date the debtor's interference took place. The creditor can demand performance, claim damages for delay, or pursue other remedies the contract or law provides. The debtor's interference does not void the contract — it triggers it. If you believe a counterparty deliberately stopped a condition from occurring to avoid their obligation, document everything you know about what they did and when. That evidence is the foundation of a claim under this article.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- International Hotel Corporation vs. Francisco B. Joaquin, Jr., et al, G.R. No. 158361, April 10, 2013 — read the decision on LawPhil →
- Development Bank of the Philippines vs. Sta. Ines Melale Forest Products Corporation, et al./Development Bank of the Philippines vs. Sta. Ines Melale Forest Products Corporation, et al, G.R. No. 193068 / G.R. No. 193099, February 1, 2017 — read the decision on LawPhil →
- Federal Corporation vs. Luwalhati R. Antonio and Eliza Bettina Ricasa Antonino, G.R. No. 199455, June 27, 2018 — read the decision on LawPhil →
- Carlos Lim, et al. vs. Development Bank of the Philippines, G.R. No. 177050, July 1, 2013 — read the decision on LawPhil →