G.R. No. L-11872, December 1, 1917
DOMINGO MERCADO and JOSEFA MERCADO, plaintiffs-appellants, vs. JOSE ESPIRITU, administrator of the estate of the deceased Luis Espiritu, defendant-appellee.

FACTS:
Plaintiffs Domingo and Josefa Mercado, along with their sisters, are the children and heirs of Margarita Espiritu, who died in 1897. Margarita owned a parcel of land in Calumpit, Bulacan, which she inherited from her father. In 1910, Domingo and Josefa executed a notarial deed of absolute sale (Exhibit 3) over their shares in the land to their uncle, Luis Espiritu, for P400. They later filed an action to annul the sale, alleging that at the time of execution, they were still minors and that Luis Espiritu induced them through fraud and cajolery to sell the land at a grossly inadequate price. They sought restitution of their shares and the products thereof.

The defendant, as administrator of Luis Espiritu’s estate, contended that the land was originally sold in part by Margarita Espiritu to Luis in 1894, and the remainder was sold under pacto de retro by the plaintiffs’ father, Wenceslao Mercado, in 1901. The 1910 deed was a ratification and absolute sale of the property. The defendant argued that the plaintiffs were of legal age or represented themselves as such when they executed the 1910 deed.

The trial court dismissed the complaint and ordered the plaintiffs to keep perpetual silence regarding the land.

ISSUE:
Whether the plaintiffs, who were minors at the time of the sale but represented themselves as of legal age, may later annul the contract and seek restitution of the property.

RULING:
The Supreme Court affirmed the trial court’s decision, denying the annulment.

The Court found that the plaintiffs, though minors in 1910, had actively represented themselves as being of legal age in the notarial deed. The evidence showed that Domingo Mercado was then about 22 years old and Josefa about 20, but both declared under oath before the notary that they were of age. The notary and Luis Espiritu had no reason to doubt their declaration, as they appeared mature and were married.

Applying principles of estoppel and good faith, the Court held that minors who falsely represent themselves as of legal age cannot later disaffirm the contract to the prejudice of the innocent party who relied on such representation. The doctrine is supported by Spanish jurisprudence (Partidas) and American authorities, which state that a minor who deceives another into believing he is of age may be barred from seeking annulment.

The Court also noted that the sale price, while lower than the assessed value, was not so inadequate as to constitute fraud, especially considering the prior transactions involving the property. Thus, the contract was valid and binding, and the plaintiffs were not entitled to restitution.

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