Short answer. No. Article 1182 provides that when the fulfilment of the condition depends upon the sole will of the debtor, the conditional obligation is void. A promise to pay only if the payer feels like paying commits him to nothing, so the law declines to treat it as an obligation at all.
What the law says
When the fulfillment of the condition depends upon the sole will of the debtor, the conditional obligation shall be void. If it depends upon chance or upon the will of a third person, the obligation shall take effect in conformity with the provisions of this Code.
Civil Code, Article 1182 — Potestative, Casual, and Mixed Conditions. Read the full provision →
Three kinds of condition, one of them fatal
The article sorts conditions by whose hands they lie in. A condition depending on chance, or on the will of a third person, is perfectly good and the obligation takes effect accordingly — approval by a bank, the arrival of a shipment, a licence being issued. A condition depending on the sole will of the debtor is void, and the reason is not fussiness. An obligation is a juridical necessity; a debtor who is bound only when he chooses to be is under no necessity at all, and the document merely records a wish.
Sole is doing as much work as will
Very few conditions are entirely within one party's control, and the article strikes down only those that are. A promise to pay when a debtor sells his lot depends on him, but also on finding a buyer at a price, so it is mixed and survives. Article 1180 shows the same instinct: rather than voiding a promise to pay when his means permit, the law reads it as an obligation with a period whose date has yet to be fixed. Courts prefer the reading that preserves the bargain, and only a genuinely empty promise fails.
What falls with the condition
It is the obligation depending on the void condition that goes, not automatically the whole agreement. Article 1183 makes the point for the related case of impossible and unlawful conditions: they annul the obligation which depends upon them, but where the obligation is divisible, the part not affected remains valid, and a condition not to do an impossible thing is treated as not having been agreed upon. So a contract with several undertakings does not necessarily collapse because one of them was written as a whim.
Drafting around it
If you are writing the clause, tie payment to something observable and dated — a milestone, a delivery, an inspection, a fixed calendar date — rather than to anyone's satisfaction at large. If satisfaction genuinely is the point, name the standard by which it is judged and who applies it. And note Article 1186, which deems a condition fulfilled when the obligor voluntarily prevents its fulfilment: a party who buries an event he was supposed to bring about gets no benefit from having done so.
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.
- Rolando T. Catungal, et al. vs. Angel S. Rodriguez, G.R. No. 146839, March 23, 2011 — read the decision on LawPhil →
- Pilipino Telephone Corporation vs. Radiomarine Network, Inc, G.R. No. 152092, August 4, 2010 — read the decision on LawPhil →
- Fidela Del Castillo Vda. De Mistica vs. Spouses Bernardino Naguiat, et al, G.R. No. 137909, December 11, 2003 — read the decision on LawPhil →
- Roberto L. Yupangco and Regina y De Ocampo vs. O.J. Development and Trading Corporation, G.R. No. 242074, November 10, 2021 — read the decision on LawPhil →
Related provisions
- Civil Code, Article 1182 — Potestative, Casual, and Mixed Conditions
- Civil Code, Article 1180 — Payment 'When Means Permit'
- Civil Code, Article 1183 — Impossible and Unlawful Conditions
- Civil Code, Article 1186 — Constructive Fulfillment