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Sps. Buenaventura Et Al. vs. CA

Plaintiffs sought to invalidate deeds of sale executed by their parents that transferred real property to their siblings. [Plaintiffs claimed this impaired their legitime share.] The court held that plaintiffs failed to prove there was no valid consideration for the deeds. Mere inadequacy of price alone is not enough to invalidate a contract of sale under Philippine law. As long as all parties believed they received the value of what they gave, the court will not intervene in the contract.

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Danica Caballes
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90 views2 pages

Sps. Buenaventura Et Al. vs. CA

Plaintiffs sought to invalidate deeds of sale executed by their parents that transferred real property to their siblings. [Plaintiffs claimed this impaired their legitime share.] The court held that plaintiffs failed to prove there was no valid consideration for the deeds. Mere inadequacy of price alone is not enough to invalidate a contract of sale under Philippine law. As long as all parties believed they received the value of what they gave, the court will not intervene in the contract.

Uploaded by

Danica Caballes
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Sps. Buenaventura et al. vs.

CA

Facts:

Defendant spouses Leonardo Joaquin and Feliciana Landrito are


the parents of plaintiffs Consolacion, Nora, Emma and Natividad as well
as of defendants Fidel, Tomas, Artemio, Clarita, Felicitas, Fe, and Gavino,
all surnamed JOAQUIN. The married Joaquin children are joined in this
action by their respective spouses.

Sought to be declared null and void ab initio are certain deeds of


sale of real property executed by defendant parents Leonardo Joaquin
and Feliciana Landrito in favor of their co-defendant children and the
corresponding certificates of title issued in their names.

Plaintiffs-appellants anchor their action on the supposed


impairment of their legitime by the dispositions made by their defendant
parents in favor of their defendant brothers and sisters. Petitioners
contended that there was no valid consideration in the conveyance or
even granting that there is, it was grossly inadequate.

Issue:

WON there is a valid consideration and assuming that there is a valid


consideration, is it grossly inadequate.

Held:

It is not the act of payment of price that determines the validity of


a contract of sale. Payment of the price has nothing to do with the
perfection of the contract. Payment of the price goes into the
performance of the contract. Failure to pay the consideration is different
from lack of consideration. The former results in a right to demand the
fulfillment or cancellation of the obligation under an existing valid
contract while the latter prevents the existence of a valid contract.
Petitioners failed to show that the prices in the Deeds of Sale were
absolutely simulated.

Petitioners ask that assuming that there is consideration, the same


is grossly inadequate as to invalidate the Deeds of Sale. Petitioners failed
to prove any of the instances mentioned in Articles 1355 and 1470 of the
Civil Code which would invalidate, or even affect, the Deeds of Sale.

Indeed, there is no requirement that the price be equal to the


exact value of the subject matter of sale. All the respondents believed
that they received the commutative value of what they gave. As we
stated in Vales v. Villa: “Men may do foolish things, make ridiculous
contracts, use miserable judgment, and lose money by them – indeed, all
they have in the world; but not for that alone can the law intervene and
restore. There must be, in addition, a violation of the law, the
commission of what the law knows as an actionable wrong, before the
courts are authorized to lay hold of the situation and remedy it.”

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