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Sps. Buenaventura v.

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

and legal basis


5. RTC: Dismissed the case.
The legitime of a compulsory heir is computed as of
the time of the death of the decedent. Therefore,
petitioners-plaintiffs cannot claim an impairment of
their legitime while their parents still live. HENCE,
THERE IS NO VALID CAUSE OF ACTION ON
THE PART OF PETITIONER SPS.
BUENAVENTURA.
The testimony of the father (respondent Joaquin)
shows that the Deeds of Sale were all executed for
valuable consideration. This assertion must prevail
over the negative allegation of petitioners Sps.
Buenaventura.
6. CA: Dismissed the case.
As compulsory heirs, petitioners-plaintiffs right to
the properties is merely inchoate, and vests only upon
the death of their parents.

Petitioners-plaintiffs are definitely not parties to the


deeds of sale. Nor do they claim to be creditors of
their parents. Therefore, they cannot be considered
as real parties in interest.

Velarde, et al., v. Paez, et al.: Those that are not


parties to, nor principally nor subsidiarily bound, do
not have legal capacity to challenge the validity of a
Deed of Sale.

(Affirmed RTC on petitioners-plaintiffs being


compulsory heirs.)
7. Hence, this case.

RULING: CA decision affirmed in toto.

If the real price is not stated, then the contract of sale is


valid but subject to reformation.

[CC 1345: Simulation of a contract may be absolute or


relative. The former takes place when the parties do not
intend to be bound at all; the latter when the parties
conceal their true agreement.]

Ladanga, et al. v. CA: If no meeting of the minds as to


price because the price stipulated is simulated, the
contract is void. [Also see CC 1471: if the price in a
contract of sale is simulated, the sale is void.]

Act of payment of price has nothing to do with perfection.


It goes into the performance of the contract.

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.

Petitioners-plaintiffs 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.

ISSUES AND RATIO:


1.WON Petitioners-plaintiffs have a legal interest over the
subject properties: NO.

Petitioners have failed to show any legal right. For this


reason alone, the trial and appellate courts should have
dismissed the action.

Kilosbayan v. Morato: Real party-in-interest: Whether he is


the party who would be benefited or injured by the
judgment, or the party entitled to the avails of the suit.

Kilosbayan v. Morato, citing Ibaez v. Hongkong &


Shanghai Bank: Real parties: those who are parties to the
agreement or are bound either principally or subsidiarily or
are prejudiced in their rights with respect to one of the
contracting parties and can show the detriment which
would positively result to them from the contract even
thought they did not intervene in it.

"Present substantial interest" is different from mere


expectancy or future, contingent, subordinate, or
consequential interest.

Definition of "present substantial interest": such interest


of a party in the subject matter of the action as to entitle
him, under the substantive law, to recover if the evidence is
sufficient, or that he has the legal title to demand and the
defendant will be protected in a payment to or recovery by
him.

3. WON the Deeds of Sale are void for gross inadequacy of


price: NO.

Petitioners-plaintiffs do not have any legal interest. Their


right is merely inchoate and vests only upon their parents
death.

Theoretically, the sale does not affect the value of the


estate: cash of equivalent value replaced the lots taken.

2. WON the Deeds of Sale are void for lack of


consideration: NO.

Contract of sale: not a real contract, but a consensual


contract.

As a consensual contract, it becomes binding and valid


upon the meeting of the minds as to price.

If there is meeting of the minds as to price, contract of


sale is valid despite: manner of payment, or even breach
of that matter.

NCC 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.

NCC 1470: 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-plaintiffs failed to prove any of the instances


mentioned in either NCC 1355 or 1470 which would
invalidate or affect the deeds.

There is no requirement that the price be equal to the exact


value of the subject matter of sale.

Vales v. Villa: There must be a violation of the law, an


actionable wrong, before courts are authorized to intervene.

The factual findings of the appellate court are conclusive on


the parties and carry greater weight when they coincide
with the factual findings of the trial court.

The trial court found that the lots were sold for a valid
consideration, and that respondents-defendants children
actually paid the stipulated prices.