11.
ROMAN CATHOLIC CHURCH v PANTE ISSUE:
GR NO. 174118
APRIL 11,2012
By: YRREVERRE
Topic: KINDS OF CONTRACTS; RESCISSIBLE CONTRACTS; VOIDABLE CONTRACTS
Petitioners: THE ROMAN CATHOLIC CHURCH, represented by the Archbishop of
Caceres
Respondents: REGINO PANTE
Ponente: BRION, J.
RECIT-READY/SUMMARY:
DOCTRINE: In the absence of any vitiation of consent, the contract between the
parties stands valid and existing.
FACTS:
 The Church, represented by the Archbishop of Caceres, owned a 32-square
meter lot located in Camarines Sur.
 The Church contracted with respondent Regino Pante for the sale of the
lot on the belief that the latter was an actual occupant of the lot.
 The contract between them fi􏰀xed the purchase price at P11,200.00, with
the initial P1,120.00 payable as down payment, and the remaining balance
payable in three years.
 However, on a later date, the Church sold in favor of the spouses Rubi a
215-square meter lot that included the lot previously sold to Pante. The
spouses Rubi asserted their ownership by erecting a concrete fence over
the lot sold to Pante, blocking the passage of Pante’s home.
 Pante instituted with the RTC an action to annul the sale between the
Church and the spouses Rubi.
 The Church 􏰀led its answer, seeking the annulment of its contract with
Pante. The Church alleged that its consent to the contract was obtained by
fraud when Pante, in bad faith, misrepresented that he had been an actual
occupant of the lot sold to him. (making it voidable)
 RTC ruled in favor of the Church, fi􏰀nding that the Church's consent to the
sale was secured through Pante's misrepresentation.
 Pante appealed to the CA - reversed the decision of RTC (valid daw kung
sale between pants and the church)
 Hence this petition.
(1) WON the contract between the Church and Pante is voidable? – No, it is valid. No
misrepresentation happened.
HELD/RATIO:
 Contract is valid, there was no vitiation of consent to make the contract
voidable. The SC stated that there could not have been a deliberate,
willful, or fraudulent act committed by Pante that misled the Church into
giving its consent to the sale of the subject lot in his favor. That Pante was
not an actual occupant of the lot he purchased was a fact that the Church
either ignored or waived as a requirement. In any case, the Church was by
no means led to believe or do so by Pante's act; there had been no vitiation
of the Church's consent to the sale of the lot to Pante.
 Contrary to the Church's contention, the actual occupancy or residency of
a buyer over the land does not appear to be a necessary quali􏰀cation that
the Church requires before it could sell its land. Had this been indeed its
policy, then neither Pante nor the spouses Rubi would qualify as buyers of
the 32-square meter lot, as none of them actually occupied or resided on
the lot.
 We 􏰀find it unlikely that Pante could successfully misrepresent himself as
the actual occupant of the lot; this was a fact that the Church (which has a
parish chapel in the same barangaywhere the lot was located) could easily
verify had it conducted an ocular inspection of its own property. The
surrounding circumstances actually indicate that the Church was aware
that Pante was using the lot merely as a passageway.
 Consent is an essential requisite of contracts as it pertains to the meeting
of the offer and the acceptance upon the thing and the cause which
constitute the contract. To create a valid contract, the meeting of the
minds must be free, voluntary, willful and with a reasonable understanding
of the various obligations the parties assumed for themselves. Where
consent, however, is given through mistake, violence, intimidation, undue
influence, or fraud, the contract is deemed voidable. However, not every
mistake renders a contract voidable.
WHEREFORE, we DENY the petition for review on certiorari, and AFFIRM the decision
of the Court of Appeals dated May 18, 2006, and its resolution dated August 11,
2006, issued in CA-G.R.-CV No. 65069. Costs against the Roman Catholic Church.