G.R. No. L-17117, July 31, 1963
ADELA SANTOS GUTIERREZ, plaintiff-appellant, vs. JOSE D. VILLEGAS and RIZALINA SANTOS RIVERA, defendants-appellants.

FACTS

The plaintiff, Adela Santos Gutierrez, and the defendants, Jose D. Villegas (surviving spouse) and Rizalina Santos Rivera, are the legal heirs of the intestate estate of Irene Santos. In January 1955, plaintiff signed a document entitled “Kasulatan Ng Bilihan At Salinan,” purporting to sell her hereditary share to her co-heir, Rizalina, for P50,000.00. She subsequently filed an action to annul this deed, alleging her consent was vitiated by fraud and mistake. She claimed she had only sought a loan from the defendants, was deceived about the document’s nature due to poor eyesight, and was misled about the true value of the estate, which she alleged was substantially higher than represented.
The defendants countered that the transaction was a genuine sale, negotiated at plaintiff’s initiative for a business venture, and that she read and signed the document knowingly. The trial court upheld the validity of the deed of sale, dismissing the complaint for annulment. However, it also dismissed the defendants’ counterclaim for moral damages and attorney’s fees. Both parties appealed the decision.

ISSUE

The primary issues were: (1) Whether the deed of sale was voidable due to fraud or mistake; and (2) Whether the contract could be rescinded as an extrajudicial partition on the ground of lesion beyond one-fourth.

RULING

The Supreme Court affirmed the trial court’s decision, upholding the validity of the sale and denying damages to the defendants. On the first issue, the Court found the plaintiff’s evidence insufficient to prove fraud or mistake. Her claim of being deceived was contradicted by evidence, including her own actions of securing a residence certificate for notarization and signing a related court manifestation. The Court emphasized that the plaintiff, an educated person, failed to exercise due diligence in ascertaining the document’s contents before signing, thus precluding a finding of vitiated consent.
On the second issue, the Court examined the plaintiff’s alternative theory that the sale should be deemed a partition under Article 1082 of the Civil Code, rescindible for lesion under Article 1098 if the value received was less by at least one-fourth of the rightful share. Assuming arguendo the transaction could be considered a partition, the Court found no basis for rescission. The evidence established the total net estate value was approximately P216,000.00. Plaintiff’s one-fourth share was thus P54,000.00. Since she received P50,000.00 from the sale, the lesion was only P4,000.00, which is less than one-fourth of her rightful share (one-fourth of P54,000.00 is P13,500.00). Therefore, the legal requirement for rescission on the ground of lesion was not met. The Court also sustained the denial of the defendants’ counterclaim for damages, finding no proof of malicious prosecution or factual basis for moral or exemplary damages.