Buenaventura v. CA (Sayson)

BUENAVENTURA v.
COURT OF APPEALS
G.R. No. 126376 20 November 2003 Carpio
Characteristics of a contract of sale: consensual Created By Frances Sayson
Void contract due to lack of consideration
Petitioners Respondents
Spouses Bernardo Buenaventura and Court of Appeals, Spouses Leonardo Joaquin
Consolacion Joaquin, Spouses Juanito Edra and and Feliciana Landrito, Spouses Fidel Joaquin
Nora Joaquin, Spouses Rufino Valdoz and and Conchita Bernardo, Spouses Tomas
Emma Joaquin, and Natividad Joaquin 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
Recit Ready Summary
The petitioners, who are four Joaquin siblings and their spouses, are seeking to declare null and
void certain deeds of sale of real property executed by the defendants, who are their parents and
seven siblings and their respective spouses. They allege that there was no actual valid
consideration for the deeds of sale and even if there was consideration, the properties were more
than three times more valuable than the values on the deeds of sale. They also allege that the
deeds do not reflect the intent of the parties and are designed to deprive them of their legitime.
The Court denied the petition. The petitioners do not have legal interest over the properties because
their rights are inchoate and vest only upon their parents’ death. The contracts of sale were not void
for lack of consideration because a contract of sale is consensual and binding upon the meeting of
the minds as to the price. It becomes void when the price is simulated. The petitioners were not able
to adequately prove that the price was simulated and that there was no meeting of the minds.
Lastly, contracts are not void for gross inadequacy of price because the general rule is that gross
inadequacy does not affect a contract of sale unless it indicates a defect in the consent or if it was
intended as a donation or another act or contract. The petitioners did not prove that their case falls
under the exceptions.
Facts of the Case
Defendants are spouses Leonardo Joaquin and Feliciana Landrito, who are the parents of co-
defendants Fidel, Tomas, Artemio, Claritas, Felicitas, Fe, and Gavino (7 children). Plaintiffs are
Leonardo and Feliciana’s other children Consolacion, Nora, Emma, and Natividad (4 children).
Six deeds of sale are being contest for the following:

1. No actual valid consideration for the deeds of sale over the properties
2. If there was consideration, properties are more than three times more valuable than the
sums on the deeds of sale
3. Deeds do not reflect true intent of the parties
4. Purported sale was a result of a conspiracy to deprive them of their legitime
The RTC and CA dismissed the case

- (RTC) Testimony of defendants show that the deeds of sale were all executed for valuable
consideration.
- (RTC) No valid cause of action because there is no legitime before death of parents
o (CA) Right to properties inchoate and vests only upon parents’ death
- (CA) Plaintiffs are not parties to the deeds of sale, nor do they claim to be creditors
Issues Ruling
1. Whether or not the deeds of sale were void for lack of consideration No
Rationale/Analysis/Legal Basis
1. No legal interest of petitioners over the properties
- Petitioner’s strategy: have the Deeds of Sale declared void so ownership will revert back to
the parents and if they die still owning the lots, all the children will co-own
- Their right to properties inchoate and vests only upon parents’ death
- Sale of lots does not affect the estate – cash replaces it
2. Contract of sale not void for lack of consideration

- Contract of sale is not a real contract but a consensual contract
o Binding upon meeting of minds as to the price
o If there is no meeting of the minds of the parties as to the price because the price is
simulated, then the contract is void
o Payment of price has nothing to do with the perfection of the contract – it goes into
the performance of the contract
- Petitioners failed to show that the price was absolutely simulated
o Plaintiff Emma’s testimony that their father told her that he will transfer a lot to her
through a deed of sale without need for her payment was not credible
o Lack of knowledge on their siblings’ financial capacity
3. Contract of sale not void for gross inadequacy of price

- Art. 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”
o Petitioners did not prove either instance
o No requirement that price equal to exact value
Disposition
CA decision is affirmed
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BUENAVENTURA v.

Six deeds of sale are being contest for the following:

The RTC and CA dismissed the case

2. Contract of sale not void for lack of consideration

3. Contract of sale not void for gross inadequacy of price

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