Pascua vs Heirs of Simeon

GR no. L-47717, May 2, 1988

Facts:
Petitioner Pascua was the debtor of Heirs of Simeon. In Civil Case 3606 a
judgment was rendered ordering Pascua to pay the heirs of Simeon in sum of
P19,720.00. To satisfy judgment, twenty (20) parcels of land belonging to Pascua were
levied upon and then sold to public auction. The highest bidder was Heir of Simeon.
When Pascua failed to redeem the properties, the Provincial Sheriff issued a Certificate
of Absolute Sale in favor of the respondent on 1972. A year after, writ of possession was
presented to Pascua, the latter refused to vacate the premises. Respondent filed Motion
to declare the petitioner contempt of court for refusing to obey the writ of possession.
Petitioner prayed that the execution sale should be set aside on the ground that
the properties sold for only P19,720.00 which is actually worth of P100,000 in 1978.

Issue:
Whether or not inadequacy of price will annul the judicial sale?

Held:
No.
It has been held that a judicial sale of real estate will not be set aside for gross
inadequacy of price unless the inadequacy be so great as to shock the conscience or
unless there be additional circumstances against its fairness.
Granting that the actual market value of the properties in 1978, or several years
after the execution sale, is the amount quoted by the petitioners, the bid price was not so
grossly inadequate as to shock the minds of impartial men, especially considering the
inflation rate during the intervening period. Besides this, the petitioners have continued
to enjoy the properties and their fruits to this date.