OBLI STUDY GUIDE: CHAPTER 3, SEC.

6 –Obligations with a Penal Clause

(Articles 1226-1230) Page 1 of 17

SECTION 6
OBLIGATIONS WITH A PENAL
CLAUSE
(Arts. 1226-1230)

STUDY GUIDE:

1. Distinguish between a principal and an accessory obligation. –

(a) Principal Obligation – one which can stand by itself and

does not depend for its validity and existence upon another
obligation.

(b) Accessory Obligation – one which is attached to a principal

obligation and, therefore, cannot stand alone.

 Example: Deo owes Zita P500,000.00 due for payment

on 31 March 2020. To secure the loan, Deo pledged and delivered to Zita
his Omega watch worth P650,000.00. Under the facts, the contract of
loan is the principal contract, while the contract of pledge is the accessory
contract.
contract

2. Obligation with a penal clause – an obligation which contains

an accessory undertaking to pay a previously stipulated indemnity in case
of breach.

3. Penal Clause - an accessory undertaking to assume greater

liability in case of breach. It is attached to the principal obligation in order
to insure its performance.

4. Kinds of penal clauses:

OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 2 of 17

(a) As to its origin :

¤ Legal – when it is provided by law; and
¤ Conventional – when it is agreed upon by the parties.

(b) As to its purpose:

¤ Compensatory (Art. 1226) – when the penalty takes
the place of damages.
¤ Punitive – when the penalty is imposed merely as a
punishment for breach.

(c) As to its demandability or effect:

¤ Subsidiary or alternative – when only the penalty will
be enforced in case of breach.
 Example: Sandra obliged herself to give Mendrad
a BMW car worth P7M on 15 March 2020. It was agreed by the parties
that if she fails to perform her obligation, Sandra will be liable to pay
Mendrad a penalty of P250,000.00. If Sandra, on due date and despite
demand, fails to deliver the car to Mendrad, she is only liable to pay him
the P250,000.00 penalty. Mendrad cannot ask for the delivery of the
BMW car, and the payment of the penalty at the same time, because the
penalty is subsidiary or alternative.

¤ Joint, cumulative or complementary – when both the

principal obligation and the penal clause can be
enforced.
 Example: Sandra obliged herself to give Mendrad
a BMW car worth P7M on 15 March 2020. It was agreed by the parties
that if she fails to perform her obligation, Sandra will be liable to pay
Mendrad a penalty of P250,000.00 in addition to her obligation to deliver
the car. If Sandra, on due date and despite demand, fails to deliver the
OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 3 of 17

car, Mendrad can demand for the delivery of the BMW car (or its value if
no longer possible) as well as the payment of the P250,000.00 penalty
because the penalty is joint and cumulative.

5. ART. 1226. –

(a) GENERAL RULE: As a general rule, in an obligation with a penal

clause, the penalty takes the place of the indemnity for damages and
the payment of interests in case of non-compliance. (Art. 1226, par.
1)

 Example: On 30 November 2018, Daryl obtained a loan of

P200,000.00 from Daria due for payment on 30 November 2019, without
need of a demand on the part of Daria. The parties agreed that if Daryl
failed to pay the loan on due date as stated in their promissory note, he
would pay a penalty of P3,000.00 per month. Daryl failed to pay the loan
on 30 November 2019, but tendered payment to Daria of his obligation on
31 January 2020. On account of Daryl’s failure to pay the loan on 30
November 2019, Daria suffered damages amounting to P30,000.00
arising from her other commitments in the course of her business
dealings. Hence, Daria was holding Daryl liable for P200,000.00 (the
principal amount) plus the P30,000.00 actual damages she suffered on
account of Daryl’s default in his obligation. Daryl, on the other hand,
claims that he should be made liable only for the amount of P200,000.00
plus P6,000.00, corresponding to two months penalty on account of delay
in making the payment.

Question: How much can Daria legally compel Daryl to pay him
under the factual circumstances obtaining in this case?
case?

Answer: Under the facts, on account of the Daryl’s delay in the

payment of his obligation from 30 November 2019 to 31 January 2020, the
loan would have borne interest for 2 months – equivalent to P6,000.00.
On the other hand, Daria suffered actual damages which she can prove
amounting to P30,000.00. However, since the penalty under the parties’
OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 4 of 17

penal clause will take the place of damages, as well as the payment of
interest occasioned by the debtor’s breach of his contract, Daryl will be
liable to pay Daria only the penalty of P6,000.00.

(b) EXCEPTIONS: Additional damages (aside from the penalty),

however, may be recovered under the following instances: (Art.
1226, par. 2)

(b.1.) Express agreement. - When the parties expressly agree that

damages or interest may still be recovered despite the
presence of the penal clause.
 A stipulation for the payment of interest apart from
interest in case of delay is not contrary to law, morals, good customs, or
public policy. For as long as the amounts stipulated are not exorbitant,
not unconscionable or contrary to morals and public policy, the court will
sustain the amounts agreed upon because obligations arising from
contracts have the force of law between the parties and should be
complied with in good faith.
 Example: On 30 September 2018, Daniel obtained a loan
from Cassey in the amount of P500,000.00 due for payment on 30
September 2019. In the promissory note signed by Daniel in favor of
Cassey, the parties agreed that if Daniel is not able to pay his obligation
on 30 September 2019, without need of any demand on the part of
Cassey, the latter can demand from Daniel the payment of P50,000.00, as
penalty, together with interest at 12% per annum on the principal amount
and the penalty computed from 30 September 2018, the day the amount
was borrowed. On 30 September 2019, Daniel failed to pay his
P500,000.00 debt to Cassey, but tendered payment to her only on 31
March 2020.
Question: Can Cassey collect from Daniel both the P50,000.00
penalty and the 12% per annum agreed interest on top of the principal
amount owing to her?
her?
OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 5 of 17

Answer: Yes. This is so because there is a stipulation

between the parties as to payment of these amounts. And since the
penalty and interest agreed upon is not unconscionable under the
circumstances, the parties will be bound by their stipulation under the
principle of the obligatory force of contracts. Under the facts, Cassey can
collect from Daniel the following amounts:
P 550,000.00 (Principal amount plus penalty agreed upon)
+ P 33,000.00 (6% interest on the principal and penalty)
P583,000.00 (Total amount payable to Cassey as of 30 March)

 READ THIS CASE IN ITS ORIGINAL TEXT:

Nicolas vs. Del-Nacia Corporation
G.R. No. 158026, 23 April 2008.

(b.2.) Refusal to pay. - When the debtor refuses to pay the penalty
imposed in the obligation, in which case the creditor may
recover legal interest thereon pursuant to Art. 2209 of the Civil
Code.

(b.3.) Debtor’s fraud. - When the debtor is guilty of fraud in the

fulfilment of the obligation, in which case the creditor may
recover damages caused by such fraud.
 This is so because any waiver of an action to enforce
liability for future fraud is void (Art. 1171) for being contrary to public
policy.

 Example: Elmer obliged himself to construct a house for

Osang which would be used to house athletes in the SEA Games. The
parties’ construction contract carried with it a penal clause which would
hold Elmer liable to pay Osang a penalty of P150,000.00 in case of his
non-compliance with the obligation. Elmer was not able to construct the
OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 6 of 17

house because he accepted a bigger contract in Dubai. As a

consequence, Osang suffered damages in the amount of P350,000.00 in
the form of lost income from the athletes.
(a) In this case, Elmer will be obliged to pay Osang the
P150,000.00 penalty. Osang cannot recover more than the P150,000.00
penalty stipulated, even if she offers proof that she suffered actual
damages amounting to P350,000.00. Neither can Elmer refuse to pay the
P150,000.00 agreed upon even if he offers proof that Osang suffered
damages less than the P150,000.00 penalty.
The penalty substitutes the indemnity for the actual damage
suffered by Osang in the amount of P350,000.00, unless there is a
stipulation to the contrary, in which case Osang may also recover the
damages proved by her.
(b) If Elmer refuses to pay the P150,000.00 penalty, Osang
may recover legal interest thereon (6% per annum), the interest
representing new damages brought about by the non-payment of the
penalty.
(c) If Elmer is guilty of fraud (not mere fault) in the fulfillment
of his obligation, he is also liable for the damages caused thereby in
conformity with Article 1171. Proof of the fraud this time, and the
existence and amount of damages, is incumbent upon Osang.
 Proof of fraud is not necessary if Osang is to recover
the penalty. All she needs to prove is the fact of breach.

2. What are the instances when the debtor is not liable to the
creditor for the payment of the penalty? –

(a) When the breach of contract is due to the fault of the

creditor.
(b) When a fortuitous event intervenes.
(c) When the debtor is not yet in default.
OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 7 of 17

 READ THIS CASE IN ITS ORIGINAL TEXT:

SSS vs. Moonwalk Development & Housing Corporation,
G.R. No. 73345, April 7, 1993.

3. ART. 1227. – The rationale for this provision is that the

precise purpose of the penalty is to secure the performance of the
principal obligation.

(a) The GENERAL RULE is that the debtor is NOT ALLOWED to just
pay the penalty instead of fulfilling the obligation. He may, however,
be EXPRESSLY granted by the creditor the right to refrain from the
execution of the contract by a forfeiture of the penalty.
(Art. 1227, 1st sentence)
RATIONALE: The penalty is not the principal obligation; hence,
the debtor cannot exempt himself from the performance of the
obligation by paying the penalty. Also, if the debtor can choose to just
pay the penalty instead of fulfilling his obligation, this would in effect
make the obligation an alternative one.

(b) The penal clause is presumed to be SUBSIDIARY or

ALTERNATIVE and NOT JOINT or CUMULATIVE (Art. 1227,
2nd sentence). – The GENERAL RULE is that the creditor does
NOT have the right to demand fulfilment of the obligation and the
penalty at the same time.
 The creditor, however, may jointly demand performance and
payment of the penalty :

(b.1.) If the right has been clearly granted to him.

(Art. 1227, 2nd sentence)
OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 8 of 17

(b.2.) If, after having required fulfilment, the performance of the

obligation should have become impossible with the debtor’s
fault, the creditor may enforce payment of the penalty.
(Art. 1227, 3rd sentence)

 Illustrative Example: On 15 January 2020, Harry

promised to deliver to Ida his Mitsubishi Pajero worth P1.5 M on 15 March
2020. The parties also agreed that should Harry fail to deliver the car on
due date, he would pay Ida a penalty of P30,000.00.
 In this case, Harry cannot just compel Ida to accept
the P30,000.00 penalty in lieu of the delivery of the car, unless he was
expressly given such right under their contract. Neither may Ida require
Harry to deliver the tractor, and to pay the penalty of P30,000.00 at the
same time, unless this right has likewise been expressly granted to him
under their agreement.
 If Harry, however, fails to deliver the car on 15 March
2020, and Ida has decided to require Harry to deliver the car instead of
demanding payment of the P30,000.00 penalty, but Harry could not
deliver the tractor because it was lost without Ida’s fault, she can also
demand the payment of the penalty of P30,000.00

 READ THIS CASE IN ITS ORIGINAL TEXT:

Dimatulac vs. Coronel, G.R. No. L-14132, January
22, 1920.

4. Enforcement of penalty when there is plurality of debtors.

–

 In Joint Obligations. - The agreement of the parties will

control the enforcement of the penalty when there is plurality of the
debtors. In the absence of such an agreement, and the penalty is joint
OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 9 of 17

each debtor is liable only for his own failure to perform and in proportion to
his share in the penalty.

 Example: Dan and Don obliged themselves to give a

Nissan Patrol car to Camila on 15 March 2020, and upon failure, to pay
her a P500,000.00 penalty. In this case, if they fail to comply with their
obligation on due date, Dan and Don can be held liable to Camila for only
P250,000.00 each because the obligation is joint.

 In Solidary Obligations. – If the obligation is solidary, the

penalty must be enforced totally because the penalty is a substitute for
losses and damages suffered by the creditor

 Example: Dan and Don obliged themselves solidarily

to give a Nissan Patrol car to Camila on 15 March 2020, and upon failure,
to pay her a P500,000.00 penalty. In this case, if they fail to comply with
their obligation on due date, either Dan or Don can be held liable to
Camila for the entire P500,000.00 penalty because the obligation is
solidary.

5. ART. 1228 – Proof of actual damages suffered by the creditor

is NOT necessary in order that the penalty may be demanded.

(a) To be able to recover the penalty, all that the creditor has to prove is
that the debtor committed a breach of his obligation.
(b) As long as there has been a breach, the creditor may enforce the
penalty whether he suffered damages or not.
(c) The creditor, however, cannot recover more than the penalty agreed
upon, even if he proves that the amount of his damages exceeds the
penalty.
(d) Then again, in any of the three exceptions when damages may be
recovered by the creditor in addition to the penalty (Art. 1226, 2nd
OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 10 of 17

sentence), the creditor is required to prove the amount of damages

he actually suffered resulting from the debtor’s breach of the principal
obligation.
6. ART. 1229 – When can the court reduce the penalty provided
for in the penal clause?
clause?

(a) When there is partial performance of the principal obligation.

 Example: Julio agreed to repaint the red car of Lyn with silver for
a contract price of P120,000.00. The parties stipulated that if Julio failed
to paint the car, he would pay a penalty of P20,000.00. Julio painted the
car, except for the inside portion of the engine hood. Since the painting of
the car is almost complete, it is not just to require Julio to pay the full
amount of the P20,000.00 as penalty. The court may reduce the amount,
say to P4,000.00.

(b) When there is irregular performance of the principal obligation.

 Example: In the above example, if Julio painted the whole car but
the color was darker than that agreed upon, the court may also reduce the
penalty. Here the painting was done completely, but there was irregular
performance.

(c) When, although there has been no performance of the principal

obligation, the penalty is iniquitous or unconscionable.
 Example: In the above example, if the penalty agreed upon is
P150,000.00, the penalty here is clearly iniquitous as it is even more than
the amount of the contract price for the painting job agreed upon.
Accordingly, the court may reduce the amount of the penalty even if there
has been no performance on the part of the debtor Julio.

 READ THIS CASE IN ITS ORIGINAL TEXT:

MCMP Construction Corp. vs. Monark Equipment Corp.
G.R. No. 201001, 10 November 2014.
OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 11 of 17

7. Obligations with a Penal Clause Distinguished from

Alternative and Facultative Obligations. –

 Obligations with a Penal Clause. - (Art. 1226)

 Example: Olive obliged herself to deliver to Marco
her Lenovo laptop worth P70,000.00. If she fails to do so, she must give
Marco P5,000.00.
 As a general rule, Olive cannot excuse herself
from the duty of giving Marco the laptop by simply paying the P5,000.00
penalty. For her to substitute the penalty, she must be expressly given
the right to do so. (Art. 1227)

 Facultative Obligations. - (Art. 1206)

 Example: Olive obliged herself to deliver to Marco
her Lenovo laptop worth P70,000.00. However, if she so desires, she
may instead give Marco P5,000.00.
 Here, Olive is clearly and expressly allowed to
make the substitution. If the laptop is lost by a fortuitous event, she is
excused from giving Marco the P5,000.00, for the principal obligation has
been extinguished.

 Alternative Obligations. - (Art. 1199)

 Example: Olive obliged herself to deliver to Marco
either her Lenovo laptop worth P70,000.00, or P5,000.00.
 Here, the choice given to Olive is absolute. If,
however, the laptop is lost by a fortuitous event, she is still obliged to
deliver to Marco the P5,000.00

8. ART. 1230 – Effect of nullity of the penal clause. -

OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 12 of 17

(a) If the principal obligation is null and void, the penal clause (which is an
accessory obligation) will have no more use for existence, and is
therefore also considered null and void. “The accessory follows the
principal.” (2nd paragraph)

 Example: On 1 March 2020, Brandon obliged himself to

deliver to Britney, on 15 March 2020, 10 kilos of marijuana worth
P150,000.00. The parties agreed on a penal clause regarding the
forfeiture of P10,000.00 in case of non-compliance with the obligation.
 Marijuana, the subject matter of the obligation, is illegal.
The penalty clause in the parties’ agreement, although in itself valid, will
also be considered null and void because “the nullity of the principal
obligation carries with it that of the penal clause.”

(b) On the other hand, nullity of the penal clause does not make the
principal obligation void. Reason: The principal obligation can stand
alone, and the void penal clause (which is subordinate to the principal
obligation) will simply be disregarded. (1st paragraph)
 Example: Gemma obliged herself to paint on canvass the
picture of Goryo and his family in their conjugal home. It was agreed that
Goryo will pay Gemma P350,000.00 for her services. In the event,
however, that Gemma fails to perform her obligation, she will be liable to
Goryo for a penalty consisting of the delivery of 5 kilos of shabu worth P5
million.
 The penalty clause here is null and void because shabu is
a prohibited substance, and its delivery is punishable by law. However,
the principal obligation of Gemma to paint the family picture of Goryo
remains valid. The penal clause will simply be disregarded, because “the
nullity of the penal clause does not carry with it that of the principal
obligation.”
OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 13 of 17

APPLICATION/PROBLEMS :

1. On 15 February 2020, Darryl obliged himself to deliver to Carlita

his BMW car worth P8 million on 15 March 2020. Darryl also bound
himself to pay Carlita the amount of P100,000.00 as penalty should he
default in the performance of his obligation. In another contract, Carlita
obliged herself to deliver the BMW car to Manuel, who was interested to
buy it for P8.5 million. On 5 March 2020, Darryl drove the BMW car after
having a few drinks with his friends in a birthday party. Darryl beat the red
light and collided with a ten-wheeler truck. Darryl survived the accident,
but the BMW car was crashed beyond recognition and repair. On 15
March 2020, Darryl could not then deliver the car to Carlita as promised.
Hence, Carlita lost P500,000.00 because her deal with Manuel could not
push through. Carlita then sought to hold Darryl liable for the actual
damages suffered by her in the amount of P500,000.00. Under the facts, facts,
how much will Darryl be liable to Carlita under their contract?
contract?  Art. 1226

2. Virgie obliged herself to pay Jun P500,000.00 on 15 June 2019,

with a penalty of P10,000.00 if she fails to pay on time. On 15 February
2020, since Virgie had not paid her obligation yet, Jun demanded payment
from her. Virgie then paid Jun the amount of P500,000.00 plus
P10,000.00 on 15 March 2020. Jun, however, avers that Virgie should
pay him P500,000.00 plus legal interest of 6% per annum as provided by
law corresponding to nine months from 15 June 2019 to 15 March 2020 –
equivalent to P22,500.00. Under the facts and the law applicable, how
much is Jun entitled to collect from Virgie on 15 March 2020? (Art.
1226)

3. On 1 March 2020, Damian obliged himself to repaint the car of

Corina, for a consideration of P80,000.00, and to finish it within 30 days.
It was also agreed by the parties that if Damian is not able to finish the
repainting job in 30 days, Damian will pay Corina a penalty of P8,000.00.
OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 14 of 17

On the eighth day of repainting, Damian informed Corina that his daughter
was treating him to a 45-day European tour. So Damian just offered to
pay Corina the P8,000.00 penalty because he could no longer proceed
with the repainting job as he was expected to fly in four (4) days. Corina,
however, refused to accept the P8,000.00, and insisted that Damian finish
the job as agreed upon. Is Corina legally justified in her demands?
demands?
(Art. 1227)

4. In the immediately preceding question, assume that Damian

wants to do the repainting job to its completion. Corina then goes to him
on the third day of work and insists that he can just pay the P8,000.00
penalty, so he does not need to continue with the repainting of her car.
Damian, however, insists that he will finish the repainting job so he can be
paid the contract price. Since Corina accedes to the payment of the
penalty instead of the performance of Damian’s obligation , can she legally
compel him to just pay the penalty instead of performing the prestation?
prestation?

5. Edgar, a faculty member of a university, is sent on a scholarship

grant under the faculty development program of the school to pursue a
doctorate degree in another school. The contract stipulates that for every
two years of study under the grant, Edgar is required to render one year of
return service, and that if Edgar violates the contract, his employment in
the university will be terminated. After four years of study, Edgar finishes
his doctorate degree. He then writes the university and, invoking the
scholarship contract, he offers that his employment in the university be
terminated. Under the facts,
facts, may Edgar be compelled to render return
service to the university?
university? (Art. 1227)

6. Engr. Deogracias obliged himself to construct a chapel for Fr.

Carlito for P3.5 million. The building contract carried with it a penal clause
to the effect that in case of breach with his obligation, Engr. Deogracias
will be liable to pay Fr. Carlito a penalty of P350,000.00. When the chapel
was two weeks away from completion, Fr. Carlito detected some
discrepancies in the construction. It was discovered that major portions of
OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 15 of 17

the chapel were not constructed according to the specifications in the

parties’ building contract. Hence, Fr. Carlito refused to pay his unpaid
balance of P800,000.00 to Engr. Deogracias, and filed a case against
Engr. Deogracias to recover the P350,000.00 penalty for breach of
contract. Will the case filed by Fr. Carlito under the factual circumstances
of this case prosper?
prosper? (Art. 1227)

7. Madig-on Furnitures undertook to deliver to Juliana a narra

twelve-seater dining set for the contract price of P300,000.00. The
parties’ agreement had a penal clause stating that any violation of the
contract would entitle the aggrieved party to damages in the amount of
P30,000.00. Three days after Juliana received delivery of the dining set,
she was told by a friend who visited her house that her dining set was not
made of narra but of another wood of inferior quality. Juliana then filed
suit to recover damages. In the hearing, she was able to prove that
because of the inferior quality of the dining set, she suffered actual
damages amounting to P150,000.00. She then prayed that the court
order Madig-on Furnitures to pay her the P150,000.00 actual damages
plus the P30,000.00 penalty, or a total of P180,000.00. Will the court be
legally justified in granting the prayer of Juliana?
Juliana? (Art. 1228)

8. Dana promised to deliver to Rommel 600 bottles of sparkling

wine worth P800,000.00 for the 70th birthday celebration of his mother. It
was stipulated by the parties that if Dana fails to deliver on the day agreed
upon, she will be liable to Rommel for a penalty of P50,000.00. On the
day of the celebration, Dana was able to deliver only 580 of the 600
bottles promised. Hence, Rommel filed an action against Dana to recover
the penalty of P50,000.00 as stipulated in the parties’ contract. Is
Rommel’s action legally justified? (Art. 1229)

9. Daniel obliged himself to sell to Chloe for P65,000.00 his

Australian kangaroo which was then pregnant. It was agreed upon by the
parties that Daniel would deliver the kangaroo to Chloe after it gave birth
or, in default thereof, to pay a penalty of P5,000.00. However, the
OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 16 of 17

kangaroo died while giving birth to its joey. Hence, Daniel was not able to
make good his obligation to Chloe. In view of the non-delivery of the
kangaroo, Chloe filed an action against Daniel for the recovery of the
penalty of P5,000.00 as stipulated by the parties in their contract. Does
Chloe’s action have legal basis? (Art. 1230)

*** END ***

HAPPY READING & LEARNING!



FOOD FOR THOUGHT

Our greatest glory is not in never failing, but in rising every time we fall.

When it is obvious that the goals cannot be reached,

don’t adjust the goals, adjust the action steps.

Real knowledge is to know the extent of one’s ignorance.

It is easy to hate and it is difficult to love. This is how the whole scheme of things works.
All good things are difficult to achieve; and bad things are very easy to get.

Confucius
OBLI STUDY GUIDE: CHAPTER 3, SEC. 6 –Obligations with a Penal Clause
(Articles 1226-1230) Page 17 of 17

Prepared by:

Atty. HRLinsangan
18 March 2020