Title
Bacala vs. Heirs of Polino
Case
G.R. No. 200608
Decision Date
Feb 10, 2021
The Supreme Court affirmed the validity of a Deed of Sale and Agreement in the case of Bacala v. Heirs of Poliño, ruling that the gross inadequacy of the purchase price did not invalidate the contract, and emphasizing the importance of evidence and burden of proof in determining the validity of contracts.
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Case Digest (G.R. No. 200608)

Facts:

  • The case "Bacala v. Heirs of Poliño" involves a dispute over the validity of a Deed of Sale and an Agreement concerning land in Cocornon, Lupon, Davao Oriental.
  • Petitioner Dioscoro Polio Bacala, acting as the substitute judicial guardian for the mentally incapacitated Aquilino O. Polio, challenged the legitimacy of these documents.
  • Initially, Aproniana Polio Balisalisa, the judicial guardian of Aquilino and Ducepino O. Polio, filed a complaint against Juan Polio and Corazon Rom.
  • The land, originally owned by Anecito and Clara Polio, was allegedly sold to Juan for P15,000.00, a price claimed to be grossly inadequate.
  • The Agreement included provisions for Anecito to enjoy the usufruct of the property during his lifetime and for Juan to provide financial support to Aquilino and Ducepino after Anecito's death.
  • The Regional Trial Court (RTC) declared the Deed of Sale and Agreement null and void due to lack of consideration and gross inadequacy of the purchase price.
  • The Court of Appeals (CA) reversed the RTC's decision, upholding the validity of the documents.
  • The case was then elevated to the Supreme Court for review.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the Court of Appeals' ruling, validating the Deed of Sale and the Agreement.
  • The Court held that the gross inadequacy of the purchase price did not invalidate the contract.
  • The Deed of Sale and the Agreement were dee...(Unlock)

Ratio:

  • The Supreme Court emphasized that a contract is presumed to be supported by an existing and lawful cause or consideration, which can only be overturned by a preponderance of evidence.
  • The petitioner failed to provide sufficient evidence to prove that the Deed of Sale was without consideration or that the transaction was simulated.
  • Notarized documents are prima facie evidence of the facts stated therein and require clear and convincing proof to be overturned.
  • The Deed of Sale explicitly...continue reading

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