GR L 46430 31; (July, 1979) (Digest)
G.R. No. L-46430-31 July 30, 1979
FRANCISCA ALSUA-BETTS, JOSEPH O. BETTS, JOSE MADARETA, ESTEBAN P. RAMIREZ, and THE REGISTER OF DEEDS FOR ALBAY PROVINCE, petitioners, vs. COURT OF APPEALS, AMPARO ALSUA BUENVIAJE, FERNANDO BUENVIAJE, FERNANDO ALSUA, represented by his guardian, CLOTILDE S. ALSUA and PABLO ALSUA, respondents.
FACTS
This case originated from two consolidated actions concerning the estate of Don Jesus Alsua. In 1949, Don Jesus and his wife, with all their living children, executed an “Escritura de Particion Extrajudicial,” partitioning their conjugal and paraphernal properties among their four children, including petitioner Francisca Alsua-Betts and respondents Amparo Alsua Buenviaje and Pablo Alsua. The agreement allocated specific properties to each heir, with the spouses reserving a portion for themselves. The deed included waivers of future claims and a penalty clause for any heir contesting its validity. After his wife’s death, Don Jesus executed two deeds of sale in 1960, conveying portions of his reserved properties to his daughter Francisca. He later executed a will instituting Francisca as his universal heir. Upon his death, Francisca sought probate of the will. The other heirs contested the probate and filed a separate action to annul the two deeds of sale, alleging the sales were fictitious, without consideration, and fraudulent.
ISSUE
The core issues were: (1) the validity of the two deeds of sale executed by Don Jesus Alsua in favor of Francisca Alsua-Betts; and (2) the propriety of allowing the probate of Don Jesus’s will. The Court of Appeals reversed the trial court, denying probate of the will, declaring the sales null and void, and awarding damages to the respondents. The Supreme Court reviewed these determinations.
RULING
The Supreme Court reversed the Court of Appeals and reinstated the trial court’s decision, thereby allowing the probate of the will and upholding the validity of the two deeds of sale. The legal logic centered on the substantive validity of the contracts of sale and the propriety of probate. The Court found the respondent court’s conclusion that the sales were fictitious and without consideration to be unsupported by the evidence. The genuineness of the deeds (Exhibits “U” and “W”) was never assailed. The consideration of P150,000.00 was sufficiently proven by documentary evidence, including checks issued by Francisca payable to Don Jesus, which he endorsed and used, notably to pay estate taxes for his deceased wife’s estate. The signature of respondent Pablo Alsua as a witness to receipts of payment further corroborated this fact.
The Court rejected the claim of fraud based on alleged inadequacy of price. Applying Article 1355 of the Civil Code, it ruled that inadequacy of consideration alone does not vitiate a contract absent proof of fraud, mistake, or undue influence. The stipulated price was not so grossly inadequate as to shock the conscience, especially since it exceeded the assessed value and the transaction was between a father and daughter, where natural affection could explain a more favorable price. The Court found no legal basis to invalidate the clearly documented sales. Consequently, having upheld the validity of the inter vivos dispositions (the sales), the Supreme Court found the Court of Appeals’ reversal of the probate proceeding and award of damages to be in error, leading to the reinstatement of the trial court’s judgment.