GR 150925; (May, 2004) (Digest)
G.R. No. 150925 ; May 27, 2004
SPOUSES JAMES TAN and FLORENCE TAN, petitioners, vs. CARMINA, REYNALDO, YOLANDA and ELISA, all surnamed MANDAP, respondents.
FACTS
Respondents are the legitimate children of Dionisio Mandap, Sr. After their parents separated, two lots adjudicated to Dionisio became the subject of dispute. Dionisio, who was totally blind since 1940 and crippled for a decade, lived with his common-law wife, Diorita Dojoles. On May 25, 1989, shortly before his death, Dionisio sold the two properties to the spouses Crispulo and Elenita Vasquez, the latter being Diorita’s sister. The titles were transferred to the Vasquez spouses.
Subsequently, on September 11, 1989, the Vasquez spouses sold one of the lots to petitioners, the spouses James and Florence Tan. Prior to this sale, on September 5, 1989, the respondents had already filed an action to annul the initial sale to the Vasquezes, alleging it was fictitious, without consideration, and vitiated by their father’s physical infirmities. They later filed a supplemental complaint to also nullify the subsequent sale to the Tans.
ISSUE
The core issues were: (1) the validity of the sale from Dionisio Mandap, Sr. to the Vasquez spouses; and (2) the validity of the subsequent sale from the Vasquez spouses to the petitioners.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ decisions, declaring both sales null and void. The legal logic proceeded sequentially. First, the Court upheld the finding that the initial sale by Dionisio Mandap, Sr. was void. The trial court’s factual findings, affirmed by the Court of Appeals, established that Dionisio was in a physically debilitated state—blind and crippled—and was under the care and influence of his common-law wife’s family. The gross inadequacy of the purchase price (₱570,000 for properties valued at ₱1.5 million) further reinforced the conclusion of undue influence and fraud, creating a presumption that the Vasquez spouses failed to rebut. A void contract produces no legal effect.
Consequently, since the Vasquez spouses acquired no valid title from a void sale, they had nothing legitimate to convey. Petitioners, as subsequent buyers, merely stepped into the shoes of their vendors. The principle of nemo dat quod non habet (no one can give what one does not have) applies. Therefore, despite petitioners’ claim of being buyers in good faith, the sale to them was also void, as the Vasquezes had no alienable right to transfer. The Court also found the award of attorney’s fees to be just and equitable under the circumstances of the case.