BUENAVENTURA vs. CA [2003] to the agreement or are bound either principally/subsidiarily.
Parties must
PETITIONERS: Sps Bernardo Buenaventura & Consolacion Joaquin; Sps Juanito Edra & Nora
Joaquin; Sps Rufino Valdoz & Emma Joaquin; and Natividad Joaquin.
RESPONDENTS: Court of Appeals; Sps Leonardo Joaquin & Feliciano Landrito; Sps Fidel
Joaquin & Conchita Bernardo; Sps Tomas Joaquin & Soledad Alcoran; Sps
Artemio Joaquin & Socorro Angeles; Sps Alexander Mendoza & Clarita Joaquin;
Sps Telesforo Carreon & Felicitas Joaquin; Sps Danilo Valdoz & Fe Joaquin;
and sps Gavino Joaquin & Lea Asis.
Facts:
⇒ Sps Leonardo Joaquin & Feliciano Landrito are the parents of petitioners.
Petitioners assail the sale of several lands by their parents to their other
siblings (see p. 265 for complete list of sales made) for being void ab initio
based on the ff grounds:
1. no actual valid consideration
2. properties are more than 3x more valuable than the measly purchase
price (purchase price was grossly inadequate)
3. deeds of sale do not reflect & express the true intent of the parties
4. deliberate conspiracy designed to unjustly deprive the rest of the
compulsory heirs of their legitime.
⇒ Defense of the respondents:
1. no cause of action, requisite standing & interest
2. sales were w/sufficient considerations & made by their parents
voluntarily in good faith & w/full knowledge of the consequences
3. certificates of title were issued w/factual & legal basis.
⇒ Trial court dismissed the case WRT Gavino Joaquin & Lea Asis. Ruled in
favor of the respondents & dismissed the complaint.
1. The rt of the compulsory heirs to a legitime is contingent & it only
commences from the moment of the death of the decedent (CC Art.
777). The value of the property left at the death of the testator is the
basis for determining the legitime (Art. 908). Plaintiffs cannot claim an
impairment of their legitime since their parents are still alive.
2. Deeds of Sale were executed for valuable consideration.
⇒ CA affirmed Trial Court decision. In addition to the grounds stated by the
trial court, CA also mentioned that:
1. While still alive, parents are free to dispose of their properties provided
such is not done in fraud of creditors.
2. Petitioners are not parties in interest since they’re not parties to the
deeds of sale nor are they creditors of their parents.
Issues & Ratio:
1. WON petitioners have a legal interest over the properties subject of
the Deeds of Sale. – NO.
⇒ The complaint betrays their motive for filing the case. They are interested in
obtaining the properties by hereditary succession but they have failed to
show any legal right to these properties.
⇒ Real party-in-interest is one who is either benefited or injured by the
judgment of the party entitled to the avails of the suit. This includes parties
have a present substantial interest & not merely expectancy/future
contingent subordinate or consequential interest.
⇒ In this case, the petitioners only have an inchoate rt w/c vests only upon the
death of their parents. Besides, sale of the lots to their siblings does not
affect the value of their parents’ estate since the lots are replaced with cash
of equivalent value.
2. WON the deeds of sale are void for lack of consideration. – NO.
⇒ A contract of sale is not a real contract but a consensual contract. It’s
binding & valid upon the meeting of the minds as to the price regardless of
the manner of payment or breach of such. It’s still valid even if the real price
is not stated in the contract, making it subject to reformation. But if the price
is simulated, there is no meeting of the minds, thus the contract is void (CC
Art. 1471).
⇒ Act of payment of the price does not determine the validity of a contract of
sale. Failure to pay the consideration is different from lack of consideration.
The former results in a rt to demand fulfillment or cancellation of the
contract while the latter prevents the existence of a valid contract.
⇒ Petitioners failed to show that the prices in the deeds of sale were
simulated. They don’t even know the financial capacity of their siblings to
buy these lots. Respondents’ minds met as to the purchase price w/c was
stated in the deeds of sale & the buyer siblings have paid the price to their
parents.
3. WON the Deeds of Sale are void for gross inadequacy of the price. –
NO.
⇒ CC Art. 1355: Except in cases specified by law, lesion/ INADEQUACY OF
CAUSE shall not invalidate a contract, unless there has been fraud,
mistake or undue influence.
⇒ CC Art. 1470: Gross inadequacy of price doesn’t 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 failed to prove any instance in the aforementioned provisions
that would invalidate the deeds of sale. There is no requirement that the
price be equal to the exact value of the property on sale. It only matters that
all respondents believed that they received the commutative value of what
they gave.
⇒ Vales vs. Villa: Courts cannot be guardians of people who are not legally
incompetent. Courts operate not because a person has been
defeated/overcome by another, but because he has been defeated or
overcome ILEGALLY. There should be a violation of the law, commission of
what the law knows as an actionable wrong, before the courts are
authorized to lay hold of the situation & remedy it.
HOLDING: CA affirmed.