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BUENAVENTURA vs. CA [2003] to the agreement or are bound either principally/subsidiarily.

Parties must
PETITIONERS: Sps Bernardo Buenaventura & Consolacion Joaquin; Sps Juanito Edra & Nora have a present substantial interest & not merely expectancy/future
Joaquin; Sps Rufino Valdoz & Emma Joaquin; and Natividad Joaquin.
RESPONDENTS: Court of Appeals; Sps Leonardo Joaquin & Feliciano Landrito; Sps Fidel
contingent subordinate or consequential interest.
Joaquin & Conchita Bernardo; Sps Tomas Joaquin & Soledad Alcoran; Sps ⇒ In this case, the petitioners only have an inchoate rt w/c vests only upon the
Artemio Joaquin & Socorro Angeles; Sps Alexander Mendoza & Clarita Joaquin; death of their parents. Besides, sale of the lots to their siblings does not
Sps Telesforo Carreon & Felicitas Joaquin; Sps Danilo Valdoz & Fe Joaquin;
and sps Gavino Joaquin & Lea Asis.
affect the value of their parents’ estate since the lots are replaced with cash
of equivalent value.
Facts:
⇒ Sps Leonardo Joaquin & Feliciano Landrito are the parents of petitioners. 2. WON the deeds of sale are void for lack of consideration. – NO.
Petitioners assail the sale of several lands by their parents to their other ⇒ A contract of sale is not a real contract but a consensual contract. It’s
siblings (see p. 265 for complete list of sales made) for being void ab initio binding & valid upon the meeting of the minds as to the price regardless of
based on the ff grounds: the manner of payment or breach of such. It’s still valid even if the real price
1. no actual valid consideration is not stated in the contract, making it subject to reformation. But if the price
2. properties are more than 3x more valuable than the measly purchase is simulated, there is no meeting of the minds, thus the contract is void (CC
price (purchase price was grossly inadequate) Art. 1471).
3. deeds of sale do not reflect & express the true intent of the parties ⇒ Act of payment of the price does not determine the validity of a contract of
4. deliberate conspiracy designed to unjustly deprive the rest of the sale. Failure to pay the consideration is different from lack of consideration.
compulsory heirs of their legitime. The former results in a rt to demand fulfillment or cancellation of the
⇒ Defense of the respondents: contract while the latter prevents the existence of a valid contract.
1. no cause of action, requisite standing & interest ⇒ Petitioners failed to show that the prices in the deeds of sale were
2. sales were w/sufficient considerations & made by their parents simulated. They don’t even know the financial capacity of their siblings to
voluntarily in good faith & w/full knowledge of the consequences buy these lots. Respondents’ minds met as to the purchase price w/c was
3. certificates of title were issued w/factual & legal basis. stated in the deeds of sale & the buyer siblings have paid the price to their
⇒ Trial court dismissed the case WRT Gavino Joaquin & Lea Asis. Ruled in parents.
favor of the respondents & dismissed the complaint.
1. The rt of the compulsory heirs to a legitime is contingent & it only 3. WON the Deeds of Sale are void for gross inadequacy of the price. –
commences from the moment of the death of the decedent (CC Art. NO.
777). The value of the property left at the death of the testator is the ⇒ CC Art. 1355: Except in cases specified by law, lesion/ INADEQUACY OF
basis for determining the legitime (Art. 908). Plaintiffs cannot claim an CAUSE shall not invalidate a contract, unless there has been fraud,
impairment of their legitime since their parents are still alive. mistake or undue influence.
2. Deeds of Sale were executed for valuable consideration. ⇒ CC Art. 1470: Gross inadequacy of price doesn’t affect a contract of sale,
⇒ CA affirmed Trial Court decision. In addition to the grounds stated by the except as may indicate a defect in the consent or that the parties really
trial court, CA also mentioned that: intended a donation or some other act or contract.
1. While still alive, parents are free to dispose of their properties provided ⇒ Petitioners failed to prove any instance in the aforementioned provisions
such is not done in fraud of creditors. that would invalidate the deeds of sale. There is no requirement that the
2. Petitioners are not parties in interest since they’re not parties to the price be equal to the exact value of the property on sale. It only matters that
deeds of sale nor are they creditors of their parents. all respondents believed that they received the commutative value of what
they gave.
Issues & Ratio: ⇒ Vales vs. Villa: Courts cannot be guardians of people who are not legally
1. WON petitioners have a legal interest over the properties subject of
incompetent. Courts operate not because a person has been
the Deeds of Sale. – NO.
defeated/overcome by another, but because he has been defeated or
⇒ The complaint betrays their motive for filing the case. They are interested in overcome ILEGALLY. There should be a violation of the law, commission of
obtaining the properties by hereditary succession but they have failed to what the law knows as an actionable wrong, before the courts are
show any legal right to these properties. authorized to lay hold of the situation & remedy it.
⇒ Real party-in-interest is one who is either benefited or injured by the
judgment of the party entitled to the avails of the suit. This includes parties HOLDING: CA affirmed.