FACTS:
The plaintiff-appellant, Mariano Guerrero, presented a document purporting to be a title to land in Caniogan, which the Court found to be a mortgage to secure a debt of 7 pesos and 5 reales. The witness, Jayme Pasion, who executed this instrument, testified that the debt had been paid. Jayme Pasion further testified that he subsequently sold the same land in Caniogan to both the plaintiff and the defendant-appellee, Antonio Miguel. The plaintiff himself informed Pasion that the defendant furnished the money for this purchase, and the document evidencing the sale was made out in the defendant’s name. The lower court found that the land in Caniogan was purchased by the defendant. It was also established that the plaintiff and defendant had an agreement where the defendant gave the plaintiff the land in Caniogan in exchange for the land that is the subject of the present litigation. The appellant argued that this contract of exchange was invalid because no document evidencing it was presented, citing Article 1280 of the Civil Code.

ISSUE:
Whether an oral contract of exchange involving land is invalid for lack of a written document, pursuant to Article 1280 of the Civil Code.

RULING:
The Supreme Court affirmed the judgment of the court below. The Court held that the fact that a contract, even one falling within the terms of Article 1280 of the Civil Code, is not in writing does not necessarily make such contract void. The Court cited its frequent prior rulings on this matter, including Soriano vs. Cortes, 8 Phil. Rep., 459. Thus, the exchange of land between the plaintiff and the defendant, despite lacking a written document, was considered valid.

G.R. No. L-3673, January 29, 1908, MARIANO GUERRERO vs. ANTONIO MIGUEL.