Miguel Katipunan v Braulio Katipunan F: Braulio Katipunan is the registered owner of a 203 sq.

m lot located at San Miguel, Manila. Dec. 1985- Braulio, assisted by Miguel and brothers Edgardo and Leopoldo Balguma as represented by their father Atty. Leopoldo Balguma entered into a contract of sale concerning said parcel of land for a consideration of 187,000 pesos. Jan. 1986- Balguma took possession of the land and start collecting the rents. March 10, 1987- Braulio filed a complaint with the RTC for the annulment of the Deed of Sale. He contends that through the insidious words and machinations of his brother and Balguma, they made him sign a document purportedly a contract of employment which turned out to be a Deed of Absolute Sale. Furthermore, it is clear that with evident bad faith, Miguel and the Balgumas conspired with one another in taking advantage of his ignorance, he being only a third grader. Petitioners denied the allegations in the complaint. They alleged that Braulio was aware of the contents of the Deed of Sale when he affixed his signature and that he received the consideration involved. RTC dismissed the complaint at first but granted the motion for reconsideration for a re-trial after it had been shown by Braulio that he had poor comprehension, him having a mental age of a 6 year old. It later on dismissed the complaint based on the merits. CA reversed the decision. Annulling the Deed of Absolute Sale basing such decision on the ground that the RTC committed a mistake by not giving weight to the testimony of Dr. Ana Revilla, a psychiatrist who was presented as an expert witness. Dr. Revilla established that Braulio has a very low IQ (he only have a mental age of a 6 year old). It was also proven that Braulio is illiterate and there is no showing that the contract were read and or explained to Braulio nor translated in a language he understood as prescribed by Art. 1332 of the NCC. Besides, Braulio can be considered an incapacitated person because of his mental age. Secondly, the consent was also vitiated by mistake or fraud because Braulio didn't know that he was actually affixing his signature on a deed of absolute sale. Such makes the contract voidable. Miguel and Balguma appealled to the SC contending that the CA should not have disturbed the findings of fact of the RTC.

I: WON contract should be annulled? H: Yes. SC affirmed the decision of the CA. Findings of fact by the trial courts can be disturbed when the trial court had overlooked, misunderstood or misapplied some fact or circumstance. Art. 1330- Consent maybe vitiated by mistake, violence, intimidation, undue influence and fraud. Based on the records of the case, it was clearly shown that Braulio signed the deed without the remotest idea of what it was --> they relied on the testimony of Braulio in Court. He was asked if he knew the document he was signing, he said he doesn't know and nobody informed him what it was. It was impossible for him to understand the contents of the contract written in English and embelished in legal jargon because he only reached grade three and has a very low IQ. Based also on the testimony of Braulio, the SC was convinced that he did not receive the purchase price. He was only given "barya-barya". They concluded that it was his brother Miguel who really wanted to go abroad and needed the money for it. SC ordered restitution of the parcels of land and of the rentals. As to Braulio, they took note of Art. 1399 exempting incapacitated persons to make any restitution except when he has been benefited by the things or price received by him. Petition denied.