GR 126376; (November, 2003) (Digest)
G.R. No. 126376 ; November 20, 2003
SPOUSES BERNARDO BUENAVENTURA and CONSOLACION JOAQUIN, et al., petitioners, vs. COURT OF APPEALS, SPOUSES LEONARDO JOAQUIN and FELICIANA LANDRITO, et al., respondents.
FACTS
The petitioners, several children of spouses Leonardo Joaquin and Feliciana Landrito, filed a complaint to annul several deeds of absolute sale executed by their parents in favor of their sibling-respondents covering various parcels of land. The petitioners alleged the sales were simulated, having no actual valid consideration, that the prices were grossly inadequate, that the deeds did not reflect the true intent of the parties, and that the transactions were a deliberate conspiracy to deprive the petitioners of their future legitime as compulsory heirs. The respondents maintained the sales were for valuable consideration, voluntary, and made in good faith.
The Regional Trial Court dismissed the complaint. It found the deeds were executed for valuable consideration based on the testimony of the father, Leonardo Joaquin. Crucially, it ruled the petitioners had no cause of action because the right to a legitime is merely inchoate and accrues only upon the death of the decedent under Article 777 of the Civil Code. The Court of Appeals affirmed the trial court’s decision.
ISSUE
Whether the petitioners have a cause of action to annul the deeds of sale executed by their parents in favor of their siblings on the grounds of simulation of contract and impairment of legitime.
RULING
The Supreme Court affirmed the rulings of the lower courts, holding that the petitioners had no cause of action. The legal logic is twofold. First, on the matter of legitime, the Court reiterated the settled doctrine that the right of a compulsory heir is contingent and vests only upon the death of the decedent. While alive, parents have absolute dominion over their property and can dispose of it through onerous contracts like sales, even if such dispositions later reduce the estate. An action for the protection of a future legitime does not accrue while the parents are still living. Second, regarding the allegation of simulation, the Court deferred to the factual findings of the lower courts, which found the sales were supported by actual and valuable consideration based on the testimonies of the vendors and vendees. The petitioners’ bare allegations of simulation, without clear and convincing proof, cannot prevail. The Court emphasized that it is not its function to re-evaluate factual evidence absent a showing of grave abuse of discretion. Since the sales were validly executed for consideration during the parents’ lifetime, the petitioners, as potential heirs, have no standing to challenge them.