GR 145874; (September, 2005) (Digest)
G.R. No. 145874. September 30, 2005. SPS. SALVACION SERRANO LADANGA and AGUSTIN LADANGA, Petitioners, vs. BERNARDO ASENETA, Respondent.
FACTS
Respondent Bernardo Aseneta, the legally adopted son and guardian of his elderly aunt Clemencia Aseneta, filed an action for reconveyance against petitioners, spouses Salvacion and Agustin Ladanga. The case involved two parcels of land in Quezon City (Diliman and Cubao properties) which were purportedly sold by Clemencia to petitioner Salvacion in 1974 for grossly inadequate prices. Respondent alleged that Clemencia, who was later declared an incompetent by the court, denied having sold the properties or receiving any payment. Petitioners claimed the sales were valid, executed out of Clemencia’s gratitude and due to her estrangement from respondent, and that they paid the consideration in cash before the notarizing lawyers.
The trial court ruled for respondent, finding no perfected contract of sale. It emphasized the gross disproportion between the alleged purchase prices and the properties’ market values, and strong indications that Clemencia did not comprehend the documents she signed. It ordered reconveyance, accounting of rentals, and payment of attorney’s fees. The Court of Appeals affirmed this decision.
ISSUE
Whether the contracts of sale over the subject properties were validly perfected.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ decisions. The legal logic centered on the essential requisites of a contract under Article 1318 of the Civil Code, particularly consent and a certain object. The Court found that consent was vitiated. Clemencia Aseneta was a 76-year-old spinster declared an incompetent, making her an easy victim of deceit. The gross inadequacy of the price (e.g., a property valued at ₱134,130 sold for ₱20,000) was not merely an unfavorable bargain but a conclusive badge of fraud, evidencing Clemencia’s lack of understanding of the contract’s import. This inadequacy shocked the conscience and rendered the contracts suspect.
Furthermore, the notarizing lawyers testified that the deeds were pre-prepared and they did not witness any payment, undermining petitioners’ claim of a consummated sale. The absence of a clear meeting of the minds on the object and consideration meant no contract was perfected. The sales were therefore voidable. As Clemencia’s legal heir and substitute, respondent had the right to seek annulment. The subsequent sale of the Diliman property by petitioners during litigation, despite a lis pendens annotation, did not moot the case; the buyer was bound by the outcome, and reconveyance to Clemencia’s estate was proper.