Beruflich Dokumente
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CA
November 20, 2003 | J. Carpio| Defective Causes and Effects - Absence of Cause
PETITIONERS: Spouses Bernardo Buenaventura And Consolacion Joaquin, Spouses Juanito Edra And Nora Joaquin, Spouses
Rufino Valdoz And Emma Joaquin, And Natividad Joaquin
RESPONDENTS: Spouses Leonardo Joaquin And Feliciana Landrito, Spouses Fidel Joaquin And Conchita Bernardo, Spouses
Tomas Joaquin And Soledad Alcoran, Spouses Artemio Joaquin And Socorro Angeles, Spouses Alexander Mendoza And Clarita
Joaquin, Spouses Telesforo Carreon And Felicitas Joaquin, Spouses Danilo Valdoz And Fe Joaquin, And Spouses Gavino Joaquin
And Lea Asis
SUMMARY: Private respondents Sps. Joaquin are the parents of petitioners Sps. Buenaventura. Sps. Buenaventura want to declare
null and void ab inition the deeds of sale of real property executed by their respondent parents. The grounds of the Sps.
Buenaventura relevant to our discussion is that there was no actual valid consideration for the deeds of sale of the properties.
Supreme Court held otherwise, stating that a contract of sale is a real contract, and not a consensual contract. For as long as there is
a meeting of the minds as to the price, the contract of sale is valid. In this case, Sps. Beunaventura failed to show that the prices
were absolutely simulated. They also lacked knowledge of their siblings financial capacity to buy the lots. The Deeds of Sale
plainly showed the cost of each lot. The purchase and real prices were stated. As of the filing of the complaint, the prices were fully
paid.
DOCTRINE: Failure to pay consideration is different from lack of consideration. Failure to pay consideration results in a right to
demand the fulfillment or cancellation of the obligation under an existing valid contract. Lack of consideration prevents the
existence of a valid contract.
FACTS:
1. Respondents Sps. Joaquin are the parents of petitioners
Consolacion, Nora, Emma and Natividad and the parents of
respondents Fidel, Tomas, Artemio, Clarita, Felicitas, Fe and
Gavino.
2. The petitioners, spouses Buenaventura (Consolacion is the
daughter of respondents huhu) are seeking to declare null and
void ab initio the deeds of sale of real property executed by
respondents Sps. Joaquin. The deeds were originally in favor
of the co-defendant children (respondents). So basically, Sps.
Buenaventura want to nullify the deeds of sale of real property
because their siblings were the ones who were originally
favored by said deeds.
3. Grounds of Sps. Buenaventura:
No actual valid consideration for the deeds of sale
over the properties in litis
Assuming there was consideration in the sums
reflected in the questioned deeds, the properties are
MORE THAN 3-FOLD TIMES VALUABLE THAN
THE SUMS THEY WERE MAKING IT APPEAR
Deeds of sale don't reflect and express the true intent
of the parties as vendors and vendees
The sale of the properties in litis was a result of a
deliberate conspiracy to unjustly deprive the rest of
the compulsory heirs (the petitioners) of their
legitime
4. On the other hand, respondents Sps. Joaquin allege that:
Petitioners have no cause of action against them as
well as the required standing and interest to assail
their titles over the properties in litis
Sales were with sufficient consideration and made
by the respondents voluntarily, in good faith, and
with full knowledge of the consequences of their
deeds of sale
Certificates of title were issued with sufficient factual
The trial court found that the lots were sold for a valid
consideration, and that respondents-defendants children
actually paid the stipulated prices.