BUENAVENTURA VS CA 416 SCRA 263 FACTS: Defen Defendan dantt spous spouses es Leona Leonard rdo o Joaqu Joaquin in and Felicia eliciana na Landri Landrito to are are the the parent parents s of plain plainti tis s Consolacion, Nora, Emma and Natividad as well as of defendants Fidel, Tomas, Artemio, Clarita, Felicitas, Fe, Fe, and avino, all surnamed J!A"#$N% &Note' (o there are two sets of children here%) (ou*ht to +e declared null and void a+ initio are certain deeds of sale of real propert e-ecuted + Leona Leonard rdo o Joaqu Joaquin in and Felicia eliciana na Landr Landrito ito in favor favor of their their co.def co.defend endant ant child childre ren n and the correspondin* certi/cates of title issued in their names% The plaintis in this case sou*ht for the declaration of nullit of the si- deeds of sale and certi/cates of title in favor of the defendants% The alle*ed that that certain deed deed of sale were were null and void void a+ initio +ecause +ecause the are are simulated% The said that' a% Firstl, Firstl, there was no actual valid consideration consideration for the deeds of sale --- over the properties in litis0 +% (econdl, assumin* that there was consideration in the sums re1ected in the questioned deeds, the properties are more than three.fold times more valua+le than the measl sums appearin* therein0 c% Thirdl, the deeds of sale do not re1ect and e-press the true intent of the parties &vendors and vendees)0 and d% Fourthl, Fourthl, the purported sale of the properties properties in litis was the result of a deli+erate conspirac desi*ned to un2ustl deprive the rest of the compulsor heirs &plaintis herein) of their le*itime% Defendants, on the other hand aver &3) that plaintis do not have a cause of action a*ainst them as well as the requisite standin* and interest to assail their titles over the properties in litis0 &4) that the sales were with su5cient considerations considerations and made + defendants parents voluntaril, in *ood faith, and with full 6nowled*e of the consequences of their deeds of sale0 and &7) that the certi/cates of title were issued with su5cient factual and le*al +asis% 8TC ruled in favor of the defendants &respondents in this case) and dismissed the complaint% #pon appeal, the CA upheld 8TC9s rulin*%
ISSUES: 3% :hether the Deeds of (ale are void for lac6 of consideration% N! 4% :hether the Deeds of (ale are void for *ross inadequac of price% N!
HELD: 1ST ISSUE: THERE WAS A CONSIDERATION. $f there is a meetin* of the minds of the parties as to the price, the contract of sale is valid, despite the manner manner of pament, or even the the +reach of that that manner of pament% $f the real price price is not stated in the contract, then the contract of sale is valid +ut su+2ect to reformation% $f there is no meetin* of the minds of the parties as to the price, +ecause the price stipulated in the contract is simulated, then the contract is void% Article 3;<3 of the Civil Code states that if the price in a contract of sale is simulated, the sale is void%
It is not th !"t o# $!%&nt o# $'i" th!t (t'&ins th )!*i(it% o# ! "ont'!"t o# s!*. =ament of the price has nothin* to do with the perfection of the contract% =ament of the price *oes into the performance of the contract% Failure to pa the consideration is dierent from lac6 of consideration% The former results in a ri*ht to demand the ful/llment or cancellation of the o+li*ation under an e-istin* valid contract while the latter prevents the e-istence of a valid contract%
+tition's #!i*( to sho, th!t th $'i"s in th D(s o# S!* ,' !-so*t*% si&*!t(. To prove simulation, petitioners presented Emma Joaquin >aldo?9s testimon statin* that their father, respondent Leonardo Joaquin, told her that he would transfer a lot to her throu*h a deed of sale without need for her pament of the purchase price% The trial court did not /nd the alle*ation of a+solute simulation of price credi+le% =etitioners9 failure to prove a+solute simulation of price is ma*ni/ed + their lac6 of 6nowled*e of their respondent si+lin*s9 /nancial capacit to +u the questioned lots% !n the other hand, the Deeds of (ale which petitioners presented as evidence plainl showed the cost of each lot sold% Not onl did respondents9 minds meet as to the purchase price, +ut the real price was also stated in the Deeds of (ale% As of the /lin* of the complaint, respondent si+lin*s have also full paid the price to their respondent father%
2ND ISSUE: THE /ENERAL RULE IS THAT INADE0UAC OF CONSIDERATION SHALL NOT INVALIDATE A CONTRACT. Art% 37@@% E-cept in cases speci/ed + law, lesion or inadequac of cause shall not invalidate a contract, unless there has +een fraud, mista6e or undue in1uence% Article 3;< of the Civil Code further provides' Art% 3;<% ross inadequac of price does not aect a contract of sale, e-cept as ma indicate a defect in the consent, or that the parties reall intended a donation or some other act or contract% &Emphasis supplied) =etitioners failed to prove an of the instances mentioned in Articles 37@@ and 3;< of the Civil Code which would invalidate, or even aect, the Deeds of (ale% $ndeed, there is no requirement that the price +e equal to the e-act value of the su+2ect matter of sale% All the respondents +elieved that the received the commutative value of what the *ave%
R*in: $n the instant case, the trial court found that the lots were sold for a valid consideration, and that the defendant children actuall paid the purchase price stipulated in their respective Deeds of (ale% Actual pament of the purchase price + the +uer to the seller is a factual /ndin* that is now conclusive upon us% :BE8EF!8E, we AFF$8 the decision of the Court of Appeals in toto%
