G.R. No. 30421, August 28, 1929
GOVERNMENT OF THE PHILIPPINE ISLANDS vs. AGUSTIN JAVIER and CORNELIA HECHANOVA

FACTS

This is a cadastral case involving the ownership of several lots. The Court of First Instance adjudicated the lots in the names of the deceased spouses Catalino Hechanova and Vicenta Guriesa. Agustin Javier, the son-in-law of Catalino Hechanova, appealed, claiming ownership of an undivided one-half interest based on a deed of sale (Exhibit B) executed by Catalino in his favor for a consideration of P2,000. The trial court found the deed null and void for lack of consideration, holding that the money was never paid. On appeal, the Supreme Court found, contrary to the trial court, that the P2,000 consideration was indeed paid by Javier to Catalino. However, the Court noted that Catalino was an old, nearly blind man at the time of the sale, that Javier was his son-in-law, and that the consideration was grossly inadequate compared to the value of the property (which was worth at least P10,000 to P15,000 for a one-half interest in 1921). The evidence also showed that Javier never took possession of the property or claimed ownership until after Catalino’s death.

ISSUE

Whether the deed of sale (Exhibit B) is valid and conveys absolute ownership of an undivided one-half interest in the lots to Agustin Javier.

RULING

No. The Supreme Court affirmed the adjudication of the lots in the names of Catalino Hechanova and Vicenta Guriesa, but modified the judgment by granting Javier a preferred lien. The Court held that while the consideration of P2,000 was paid, the deed cannot be sustained as a conveyance of absolute legal title due to the gross inadequacy of the price, the advanced age and near-blindness of the vendor, and the fiduciary relationship arising from Javier being the vendor’s son-in-law. These circumstances indicate that Catalino never intended to make an absolute conveyance for such a nominal sum, and Javier drove an unconscionable bargain. Consequently, Javier is not declared an owner but is granted a preferred lien on an undivided one-half interest in the lots for the amount of P2,000, with 6% interest from the date of the deed (April 15, 1919). This lien must be noted on the certificate of title, and Javier is given the right to enforce it through a sale of the property if not paid within ninety days after the judgment becomes final. No costs were awarded.