Mercado and Mercado vs. Espiritu (37 Phil.

215)
Facts:
Domingo and Josefa Mercado, along with their sisters Concepcion and Paz, were the heirs of
Margarita Espiritu.
Margarita died in 1897, leaving a 48-hectare land as her paraphernal property.
In 1910, Domingo and Josefa, claiming to be of legal age, executed a deed of sale of their share
of the land to Luis Espiritu for P400.
Domingo and Josefa later filed a complaint to annul the sale, alleging they were minors at the
time of the sale and that the price was grossly inadequate.
Luis Espiritu died, and the case was continued against his administrator, Jose Espiritu.
Issue:
Whether the deed of sale executed by Domingo and Josefa Mercado was valid despite their
alleged minority at the time of the execution.
Supreme Court Ruling:
No proof of minority: The plaintiffs (Domingo and Josefa) failed to present sufficient evidence to
prove their minority at the time of the sale. They only relied on the statement of one of the adult
parties, referencing notes in a private book, which was not considered sufficient proof.
Estoppel: The Supreme Court applied the doctrine of estoppel, stating that minors who present
themselves as of legal age and enter into contracts are bound by their actions.
Valid sale: The sale of real estate by minors who present themselves as of legal age, even if they
are not, is considered valid. They cannot later claim annulment or excuse themselves from
fulfilling their obligations.
Judgment:
The Supreme Court affirmed the lower court's decision, dismissing the complaint and upholding
the validity of the sale. Domingo and Josefa were estopped from claiming their minority and
were held liable for the sale of their share of the land to Luis Espiritu.
Suntay vs. CA (251 SCRA 430)
Facts:
Federico Suntay, a wealthy landowner, owned a parcel of land with a rice mill and warehouse.
He wanted to become a miller-contractor for the National Rice and Corn Corporation (NARIC)
but was rejected due to outstanding loans.
To circumvent this, he allowed his nephew and lawyer, Rafael Suntay, to apply for the license in
his behalf.
They executed a deed of sale transferring the land to Rafael for P20,000.
Three months later, Rafael executed a counter-sale, selling the land back to Federico for the same
price.
The counter-sale was not properly notarized and registered, and Federico remained in possession
of the property.
Federico filed a complaint for reconveyance and damages, claiming the sale was simulated.
Issue:
Whether the deed of sale between Federico and Rafael was a simulated transaction.
Supreme Court Ruling:
The sale was simulated: The Court found several indicators of simulation, including:
The grossly inadequate consideration of P20,000 for a valuable property.
The close timing of the sale and repurchase at the same price.
Rafael's failure to take actual possession of the property despite being the registered owner.
The lack of evidence that Rafael paid for the property or that Federico received any
consideration.
The deed of sale was null and void: The Court held that the sale was intended only for
accommodation and had no legal effect.
Federico was entitled to reconveyance and damages: The Court ordered Rafael to reconvey the
property to Federico and to pay damages for the latter's expenses in pursuing the case.
Judgment:
The Supreme Court affirmed the CA's decision, declaring the deed of sale simulated and null and
void. Federico was awarded reconveyance of the property and damages.
Manila Banking Corporation vs. Silverio (G.R. No. 132887, August 11, 2005)
Facts:
Purificacion Ver owned two parcels of land in Parañaque City.
She sold the land to Ricardo Silverio, Sr. in 1979, but the deed of sale was not registered.
In 1990, Manila Banking Corporation (MBCC) filed a collection suit against Ricardo, Sr. and
obtained a writ of attachment on the land.
Ricardo, Sr.'s nephew, Edmundo Silverio, claimed he bought the land from his uncle in 1989 and
requested MBCC to cancel the attachment.
Edmundo filed a petition to cancel the attachment, arguing he was the rightful owner.
The trial court dismissed Edmundo's petition, finding the sale to him was simulated.
The Court of Appeals reversed the trial court's decision, ordering the cancellation of the
attachment.
Issue:
Whether the sale of the land from Ricardo, Sr. to Edmundo was simulated.
Supreme Court Ruling:
The sale was simulated: The Supreme Court agreed with the trial court's finding that the sale was
simulated.
MBCC had the right to attach the property: Since the sale was simulated, Ricardo, Sr. remained
the owner of the land, and MBCC had the right to attach it.
Third parties can challenge simulated contracts: MBCC, as a creditor, had the right to challenge
the simulated sale even though it was not a party to the transaction.
The Court of Appeals erred in reversing the trial court's decision.
Judgment:
The Supreme Court reversed the Court of Appeals decision and reinstated the trial court's
decision. The attachment on the land remained valid, and Edmundo's petition to cancel it was
dismissed.
Blas vs. Santos (1 SCRA 899)
Facts:
Simeon Blas married Marta Cruz and they had three children, one of whom, Eulalia, had children
of her own, including Maria Gervacio Blas.
Marta Cruz died in 1898. Simeon Blas then married Maxima Santos in 1899.
Simeon Blas died in 1937, leaving a will where he bequeathed half of his conjugal property to
Maxima Santos and the other half to pay debts and to specific heirs and legatees.
Before his death, Simeon Blas had his son-in-law, Andres Pascual, prepare a document (Exhibit
"A") where Maxima Santos promised to respect his will, hold half of her share of the conjugal
property in trust for his heirs and legatees, and convey it to them in her own will.
Maxima Santos died in 1956. She did not fulfill her promise in her will, leaving only a small
portion of her property to Simeon Blas's heirs.
Issue:
Whether the heirs of Simeon Blas could enforce Maxima Santos's promise to convey half of her
share of the conjugal property in her will.
Supreme Court Ruling:
The document (Exhibit "A") signed by Maxima Santos was a valid compromise and contract
with sufficient cause and consideration.
The action to enforce Maxima Santos's promise did not arise until her death, when it was
discovered she did not comply with her promise.
The Court found that the promise was not a contract on future inheritance, as it was not a
property or right not in existence or capable of determination at the time of the contract.
The Court concluded that Maxima Santos's promise was a valid obligation that her heirs were
bound to fulfill.
Judgment:
The Supreme Court reversed the lower court's decision and ordered the administratrix of Maxima
Santos's estate to deliver one-half of the properties left by Maxima Santos to the heirs of Simeon
Blas, as per the promise made in Exhibit "A."