Buenaventura vs CA (Case Digest)
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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;