Wednesday, March 07, 2012

Spouses Buenaventura vs. CA

Facts: 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. The petitioners contend that there was no actual valid consideration and that assuming that there was consideration in the sums reflected the properties are more than three-fold times more valuable than the small sums appearing therein. The RTC ruled in favor of the defendants and dismissed the case. RTC’s ruling was affirmed by CA. Hence the appeal. 

Issue:Whether or not there was a valid consideration in the deeds of sale

Held: If there is a meeting of the minds of the parties as to the price, the contract of sale is valid, despite the manner of payment, or even the breach of that manner of payment. If the real price is not stated in the contract, then the contract of sale is valid but subject to reformation.

Art. 1355. Except in cases specified by law, lesion or inadequacy of cause shall not invalidate a contract, unless there has been fraud, mistake or undue influence.

Article 1470 of the Civil Code further provides:Gross inadequacy of price does not affect a contract of sale, except as may indicate a defect in the consent, or that the parties really intended a donation or some other act or contract.

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.

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